4 replies to this topic

[DocGra]

Hello

We make a wide range of preserves, chutneys and acidified sauces from more than 200 different ingredients, all of which have their suppliers specifications, most of which provide a statement of microbial activity on delivery.

Virtually all our products are heat processed (cooked) and most are hot filled and have pH<3.5. Some have 3.5<pH<4.1 and undergo an additional 6-log pasteurisation process (Tref=93.3C, z=8.3C) after hot filling and sealing to do even more lethal damage.

How do we set pragmatic 'site standards' for ingredient microbial contamination levels for our ingredients without setting them 'per ingredient'?

We understand the link between initial microbial loads and delivered lethality in our thermal processes - but want to avoid the complications of D values in different pH regimes. Life is already complicated enough with so many ingredients!

Currently we classify our ingredients (raw fruit, spices, pre-processed (canned, sugar etc) etc) but we risk rejecting some so we can maintain a relatively low microbial threshold. For instance we want to use mushrooms in a sauce and their supplier even appears to tolerate the presence of E.coli, Salmonella and Listeria monocytogenese!

If we 'lift' the reject level to avoid rejects - why have a reject level?

Routine micro includes finished products and ingredient samples (as well as end-of-life products, equipment swabs, air plates, water samples, hand swabs, drain swabs etc), almost the only 'micro positives' relate to raw ingredients (OK - we get occasional issues with drains and machine surfaces - but they reflect cleaning efficacy more than cross contamination from ingredients).

Our finished product microbiology conforms with the IFST guidelines - we cook 'very well' and (shhhh .. they are listening - so don'tread this bit out loud!!) we haven't had a finished product micro positive for more than 2 years - so should we be too concerned about incoming ingredient microbiology?

We've searched the literature and sought advice from real microbiologists but we have so far failed to identify a simple pragmatic approach that we would feel confident of defending in front of our next BRC auditor.

I'm hoping there are a few practical 'foodies' out therethat will be prepared to share their experiences - please

Thanks in advance

Graham

[Charles.C]

Dear DocGra,

We've searched the literature and sought advice from realmicrobiologists but we have so far failed to identify a simple pragmatic approach that we would feel confident of defending in front of our next BRCauditor.

I suggest you post a typical example of one of yr current product / microbiological specifications so that posters can comment on it. Otherwise it’s rather difficult to know yr specific concerns.
(Sorry I hv no idea what the current IFST specs are since I believe these are unpublished ???)

IMEX, it is more common that a receiver initiates the discussion on micro.reqs since he/she often hv more access to possible legislatory requirements / technical issues / intended usage of final product. The usual consequence is a discussion with supplier on certain points with an eventual agreed set of numbers (or not ).

It is almost inevitable that different ingredients will have different levels of microbiological specifications. I’m sure you realise that, especially where raw, processed, canned items are all involved.

With regard to typical micro.specs, not sure if you are aware that reference sources for raw materials do exist and hv been posted here occasionally, eg the ICMCF series of books.
However I agree that experts do not always agree except (usually) for pathogens such as Salmonella, such is the world of geographical microbiology. No doubt the FSA know more about UK situation than I. IMEX, auditors typically require to see a realistic source / basis for issued micro.specs since they often know far less on the specific products than the auditee.

Not an expert on chutney but your quoted pasteurisation process, eg 6D, is presumably predicated with the assumptions of the L.mono based logic in UK. The theory behind such requirements necessarily includes considerations for potential (eg L.mono) input loads plus achieving acceptably low levels after pasteurisation. For Salmonella/USA, the detailed theory is available on the IT. I think that Codex set the groundwork for L.mono many years ago (inc. in the EC 2005-6 Food document perhaps?) but no doubt FSA hv published details somewhere. Expressed very crudely, the argument is like, suppose you know that your input material can exhibit a L.mono level up to 10 cfu/gm, then following a 6D reduction, should have maximum 10^(-5)cfu/gm coming out. The question then becomes whether the latter value is acceptable and this is where opinions can sometimes vary. This logic is not oriented to setting acceptance levels in input material per se, it is designed to (realistically) inform you as to the suitability of yr intended pasteurisation process to achieve yr intended finished product specification, eg "absence" of L.mono. The conceptual subtleties are discussed in detail in ICMCF series book 8 (from memory).

their supplier even appears to tolerate the presence of E.coli, Salmonella and Listeria monocytogenese!

I am indeed surprised that any supplier of raw material (excluding chicken perhaps) would offer a spec. with a (considered) acceptable positive level of Salmonella (even if realistic). Even more surprised if you accepted such. The general significance of your comment may relate to the item’s production history, eg textbooks often suggest that micro.specs for pathogens in unprocessed raw materials from the ground are of limited value.

Rgds / Charles.C

[DocGra]

Hello Charles,

Thank you for your post and views, we were also more than a bit surprised to find salmonella amongst the organisms likely to inhabit mushrooms offered for sale - we decided it indicated more about the supplier!

Totally understand your notes re microbial population reduction and the statistical survival probability of an initial population in a given process regime. This is our current approach but as you can imagine, it requires a product by product study of every ingredient, considered individually in the context of the thermal process and the acidification regime(given microbial death kinetics are a function of pH and the majority of ourproducts have different acidification regimes). In addition, given our finished product list is significantly larger than our list of ingredients, we would need to consider many ingredients in more than one situation and that furtherc omplicates the apparently simple task of setting reject levels for incoming ingredients.

We'll look up some or your really useful pointers to the literature and search through the online US FSA data. Here in the UK, regulatory information is not so prescribed so we often find a US view very informative.We usually debate relevance in the context of UK/EU regulations but we always learn something to our advantage. I must admit we have already made a bit of a'sweep' but we've not looked properly - so that will be my task this weekend.

Appreciate your auditor comment too - it made me smile - ourworst fear is to have a microbiologist turn up to our next BRC audit!

Kind regards,

Graham

[SUSHIL]

Hello

We make a wide range of preserves, chutneys and acidified sauces from morethan 200 different ingredients, all of which have their suppliersspecifications, most of which provide a statement of microbial activity on delivery.

Virtually all our products are heat processed (cooked) andmost are hot filled and have pH<3.5. Some have 3.5<pH<4.1 and undergo anadditional 6-log pasteurisation process (Tref=93.3C, z=8.3C) after hot fillingand sealing to do even more lethal damage.

How do we set pragmatic 'site standards' for ingredientmicrobial contamination levels for our ingredients without setting them 'peringredient'?

We understand the link between initial microbial loads and delivered lethality in our thermal processes - but want to avoid the complications of D values in different pH regimes. Life is already complicated enough with so many ingredients!

Currently we classify our ingredients (raw fruit, spices, pre-processed (canned, sugar etc) etc) but we risk rejecting some so we can
maintain a relatively low microbial threshold. For instance we want to use mushrooms in a sauce and their supplier even appears to tolerate the presence of E.coli, Salmonella and Listeria monocytogenese!

If we 'lift' the reject level to avoid rejects - why have areject level?

Routine micro includes finished products and ingredientsamples (as well as end-of-life products, equipment swabs, air plates, watersamples, hand swabs, drain swabs etc), almost the only 'micro positives' relateto raw ingredients (OK - we get occasional issues with drains and machinesurfaces - but they reflect cleaning efficacy more than cross contaminationfrom ingredients).

Our finished product microbiology conforms with the IFSTguidelines - we cook 'very well' and (shhhh .. they are listening - so don'tread this bit out loud!!) we haven't had a finished product micro positive formore than 2 years - so should we be tooconcerned about incoming ingredient microbiology?

We've searched the literature and sought advice from realmicrobiologists but we have so far failed to identify a simple pragmaticapproach that we would feel confident of defending in front of our next BRCauditor.

I'm hoping there are a few practical 'foodies' out therethat will be prepared to share their experiences - please

Thanks in advance

Graham

Dear DocGra,

Your products chutneys and preserves contain high amount of sugar-Brix>60 (preservatives),and low ph <4.5 are basically low risk products,as they will be unable to support bacteria but likely to support yeasts and molds after opening bottles and storage of opened bottles.

Similarly,sauces (like tomato-ketchup etc) though acidic and hot filled (killing of micro).are prone to yeast and mold attacked after opening.

Also,MAYONNAISE sauce though acidic, contain eggs/pasteurised eggs for emulsification of oil and spices.

All the above products have HACCP Plans and PRPS (GMP,GHP,SANITATION,PERSONNEL HYGIENE ETC).

Ccps- Ph,temp,salmonella (eggs),Listeria etc Certificate of analysis from supplier etc(free of pathogens-like E.coli,salmonella,staph-aureus,listeria etc.)

Spices are most commonly used for above products and may be likely contaminated with above pathogens since they are of agricultural origin and directly added to chutneys and preserves.Also some varieties/species of mushrooms are poisonous.

Presently,all food manufacturers ,irrespective of products,follow food safety quality managements,supplier quality assurance,etc.

1. HACCP/Quality system

2. Factory premises/location

3. Hygiene of personnel

4. Infestation/foreign body control

5. Raw materials control

6. Production & process control

7. Product analysis & quality assurance

8. Product storage and distribution etc.

Products recalls have become very common these days mostly having microbiological contaminations like Salmonella,E.coli,Listeria : AND Allergen contaminations and many big companies are also involved in these product recalls.
Hence all countries have food safety regulations.
Cross Contaminations can occur in food Manufacturers premises through personnel,aerial route,forklifts ,equipments and lot of other factors.
Hence you cannot risks raw-materials containing listeria ,salmonella etc coming in to your food premises even if you have heat processes In place.
Hazard analysis of raw materials used in finished products is essential part of food safety.
Since you don’t have problems for last two years is because of rejections.You have to follow strict food safety policies,irrespective of food products categories. (low,medium,high risk)

Regards

Sushil

[DocGra]

Thank you Sushil,

Appreciate your comments and Thank you for confirming we are more or less on the right lines.

We have already put HARA based controls into place re incoming pathogens - but I must admit our 'purchasing from approved suppliers' and 'ingredient specification', pre-requisites serve our HACCP - rather than installing a CCP at the point of entry to the site. In fact it was these HARAs that gave rise to the need to set reject levels for our ingredeints (action limits).

We have recently 'beefed-up' our cleaning protocols and gone to some length to demonstrate their efficacy - so now we have documented and validated strategic cleaning bewteen batches as well as envorionmental cleaning programmes to maintain cross contamination controls. We've also studied the potential for pre-process and post process cross contamination and altered the factory layout and handling protocols to improve segregation.

We take 'due diligence' very seriously; we strive to ensure what ever can be done - is actually done - and recorded, validated and audited too!

Thank you again for your valued inputs

kind regards,

Graham