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Can pests infestation be considered as a critical control point?


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#1 Bhawani Gorti

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Posted 29 March 2014 - 10:57 AM

Dear Simon

Can you help me in this........

CASE STUDY

I am working on wheat grain silo project which is planning to go for BRC Storage and Distribution certificate. Wheat being a agriculture commodity passes through several intermediate traders and various storage practices. By the time it comes to our Silo site we have lot of pest infestation affected. This is spreading to all other silo storage. We can treat fumigation to limited extend only. We will be transferring wheat stock from Silo to Flour Mill for milling purpose. Same wheat stock when comes to Mill having more pest infestation.                                                                                                                  

 

So would like to know more inputs on how to control of pest infestation in incoming of wheat stock and outgoing of wheat stock from Silo to Mill.                

                                                                               

Based on Codex HACCP - Wheat is going from silo which has RA-3 hence fumigation is essential steps to reduce to acceptable level of pest infestation. When wheat enters Mill (FSSC22000 Standard) based on 7.4.4 clause is applicable. At this stage categorization of control measures shows fumigation stage is a CCP.

If we declare it as CCP – It will be difficult to run Mill production. What to do?         

 

                                                                                

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#2 Charles Chew

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Posted 30 March 2014 - 10:45 AM

Hi,

 

Pest control is a PRP so its not really part of your product transformation process. Frankly, it is impossible to classify this activity as a CCP.


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Charles Chew
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#3 rfr429

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Posted 30 March 2014 - 01:56 PM

I think its not a CCP. The pest infestation can be managed with a good pest control management from your supplier and your plant



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#4 mesophile

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Posted 30 March 2014 - 05:46 PM

Definitely not a CCP. This is a pre-requisite.

 

You need tighter control with your suppliers - if you are purchasing products known to have pest infestations then why are you buying them? You must have a supplier approval process with supplier non-conformances? If you are going for BRC Storage and Distribution, these points will be raised and you will get most likely receive a major if you cannot demonstrate control with your suppliers.



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#5 Charles.C

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Posted 30 March 2014 - 05:46 PM

Somewhat unclear whether response is required with respect to  BRC storage-distribution, FSSC 22000, both (?). i assume the middle one as per end text of the OP.

 

(1) Agreed it is a PRP as per iso 22000, para 7.2.3(i) or iso 22002-1, section 12.

(2) It also appears to be a PRP which has failed “planned verification” as per iso 22000 [7.2.3,7.8(a)]

(3) The activities subsequent to (2) are presumably dictated by  iso 22000, section 8.4. [eg due 8.4.2© et al]

 

Basically correction of the specific defect is required together with any correlated hazards. Plus a review and updating (if necessary)   of the overall FS plan.

 

Rgds / Charles.C

 

PS - the PRPs should be implemented prior to the hazard analysis shown in yr attachment.


Kind Regards,

 

Charles.C


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#6 Mr. Incognito

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Posted 31 March 2014 - 11:58 AM

I work in flour milling and I agree with the above posters that Pest Control is a PRP not a CCP. 

 

In our system we pull some wheat out of the delivery truck for testing and if one bug is found in the wheat pulled the truck is rejected for infestation (this does not happen very often). 

 

We get wheat from multiple suppliers and I know what your talking about how wheat may be in multiple hands before it comes to you.  Many times growers send them to different elevators and brokers sell you the wheat from those elevators.  They are loaded on multiple trucks between the field and the mill.  Any spot where infestation happens can really cause a widespread problem throughout the food chain.

 

It really has to come from a culture of keeping pest issues low throughout the industry.  I obviously don't know much about the market in India on how much pests are prevalent in the wheat industry there.  However you can start with rejecting any loads that have pests in them.  You could try to install a cleaning house between receiving and your receiving silo bank and clean it before it goes into the silos which might help some with pests.  We are lucky being in the frozen north where around 1/2 the year pests are dormant.

 

I haven't been in flour for very long so I don't know how realistic what my suggestions are for you but I hope that you find the answers your looking for.


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#7 debaduttajayaprakash

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Posted 31 March 2014 - 01:04 PM

For BRC S&D certainly you have to make sure that all control and corrective action is in place for pest affected goods in Goods In point. 

If you do not have anything in place to clean the pest infestation before it goes into the silo  then it will be part of your PRP . From historical data you can set critical limits, frequency of checking , checking method , corrective action and documentation . You need to make sure that in Goods in Point the documentation is well connected with your Quality Management system and fumigation method is well calibrated along with vehicle inspection before unloading goods at your site. 

this PRP step can again be documented at Hazard analysis section on Goods In , where the set PRP is maintained and product approval is done for each supplier ( Where supplier are traders give a brief description  of storage condition between field and your site , to identify each hazard along with pest hazard ) , perform a risk assessment and you can still put it under significance risk but can justify in CCP determination step as a minor and PRP is enough   to justify your target measure and control process . This will help you to get the step out of the way to be CCP which can help your process side and you can put extra documentation and checking schedule on your PRP. 

I am not much sure as my expertise is in spice and herb product but infestation is an issue when importing goods from Outside EU .

Also if the final product is going through further processing such as cooking , baking , etc then the measure risk associated with rodent dropping and urine is salmonella which will eventually get killed. But your final product needs to be infestation free to a naked eye. 



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#8 philip

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Posted 31 March 2014 - 01:25 PM

Well you seem for once to have absolute unanimity in response - it is a hazard managed by your prerequisite programm. 

You may however be a little unsure as to how you got to the CCP conclusion where nobody else did. You should understand that as well for future decisions.

Basically, you fell down on the early part of your decision tree.  Specifically there should be a question along the lines of ... " is the hazard controlled as part of a pre-requisie programme?"  If you answered "Yes",  then thats the end of it.  Clearly pest control should be managed as a PRP, even when dealing with the raw material being delivered and stored.   If you were in a weird position of not having any PRPs,you would have no option but to use fumigation as the control, but then would you want to be a food manufacturer in that situation?

One other point about CCPs - the question you asked about being essential is better asked "Is the control essential in itself" before finalising as a CCP



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#9 swanswal

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Posted 02 April 2014 - 08:43 PM

I would also add that you have a close look at your material specification. It sounds like there is no mention of presence of stored product pests, live or dead.

Before you start rejecting loads or making too much fuss, get your spec right first.

Cheers



#10 Bhawani Gorti

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Posted 06 April 2014 - 06:14 AM

For BRC S&D certainly you have to make sure that all control and corrective action is in place for pest affected goods in Goods In point. 

If you do not have anything in place to clean the pest infestation before it goes into the silo  then it will be part of your PRP . From historical data you can set critical limits, frequency of checking , checking method , corrective action and documentation . You need to make sure that in Goods in Point the documentation is well connected with your Quality Management system and fumigation method is well calibrated along with vehicle inspection before unloading goods at your site. 

this PRP step can again be documented at Hazard analysis section on Goods In , where the set PRP is maintained and product approval is done for each supplier ( Where supplier are traders give a brief description  of storage condition between field and your site , to identify each hazard along with pest hazard ) , perform a risk assessment and you can still put it under significance risk but can justify in CCP determination step as a minor and PRP is enough   to justify your target measure and control process . This will help you to get the step out of the way to be CCP which can help your process side and you can put extra documentation and checking schedule on your PRP. 

I am not much sure as my expertise is in spice and herb product but infestation is an issue when importing goods from Outside EU .

Also if the final product is going through further processing such as cooking , baking , etc then the measure risk associated with rodent dropping and urine is salmonella which will eventually get killed. But your final product needs to be infestation free to a naked eye. 

Thanks for reply. Sorry could not able to reply back immediately. I have gone it and making changes in our procedure based on your suggestion.....once again thanks. can u give ur mobile contact no...


B T Gorti
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Skype id-Saradiro Services
website-www.saradiro.com


#11 rmyslik

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Posted 11 April 2014 - 04:57 PM

Dear Simon

Can you help me in this........

CASE STUDY

I am working on wheat grain silo project which is planning to go for BRC Storage and Distribution certificate. Wheat being a agriculture commodity passes through several intermediate traders and various storage practices. By the time it comes to our Silo site we have lot of pest infestation affected. This is spreading to all other silo storage. We can treat fumigation to limited extend only. We will be transferring wheat stock from Silo to Flour Mill for milling purpose. Same wheat stock when comes to Mill having more pest infestation.                                                                                                                  

 

So would like to know more inputs on how to control of pest infestation in incoming of wheat stock and outgoing of wheat stock from Silo to Mill.                

                                                                               

Based on Codex HACCP - Wheat is going from silo which has RA-3 hence fumigation is essential steps to reduce to acceptable level of pest infestation. When wheat enters Mill (FSSC22000 Standard) based on 7.4.4 clause is applicable. At this stage categorization of control measures shows fumigation stage is a CCP.

If we declare it as CCP – It will be difficult to run Mill production. What to do?         

You had a lot of good answers to think about. The one response mentioned the supplier. That is key. If you hold the supplier to the highest standards possible problems will diminish and go away from these suppliers. If you don't hold them accountable then this problem will continue to arise and you have enough to worry about. In the US companies are very strict as to who they get supplies from, as a matter of fact they hold not only food products (raw or finished) to the highest standards but also the packaging, labeling and any other company that will effect the product they are involved with. 






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