20 replies to this topic

[paconmatt]

In the consolidated standards it specifically starts the Microbial Control Program with IF NEEDED and it mention something about containers.  I could see where this would apply for say milk jugs, soda bottles, etc. but at our facility we extrude net and film.  We don't manufacture containers of any kind we manufacture net bags.  With all this said I don't feel that we need a microbial control program.  But I'm not sure how the inspector is going to perceive my opinion.  So, I guess what I'm asking is what is the definition of IF NEEDED because I don't feel we need it but I'm still worried.

[Dharmadi Sadeli Putra]

Dear Paconmatt,

 

The best way is do Hazard Analysis to determine whether Microbial Control Program is needed by your facility

Good luck

 

Rgds,

Avila

[paconmatt]

Avila,

 What type of information needs to be recorded in a Hazard Analysis.  Is there some type of measureable data needed?  Or does this analysis just made up of a collective opinion from our company? 

[Snookie]

If the netting holds things like raw onions, microbes are probably not an issue.  But then again, if your net is getting contaminated and creating a huge load...then it might be an issue. 

 

If your film is used for example to be heat sealed to a tray, then microbes might be an issue. 

 

 

There is not enough information to tell if you need to do this or not and what you need to do.   If not you need to be able to demonstrate that you have verified and validated why it is not a risk. 

[Dharmadi Sadeli Putra]

Paconmatt,

As Snookie said, intended use of your products determine whether you need a microbial control program or not. If it only being used for holding raw materials then cGMPs implementation is enough. If it is used for RTE, then you need to conduct Hazard Analysis (chemical, microbial, physical hazards)

[Charles.C]

Dear paconmatt,

 

I'm unclear as to how many people here are actually using AIB packaging standard (or any AIB standard) but i suspect very few (??). This is in no way to decry the value of any/all suggestions, the exact opposite, but do be aware that the exact requirements / interpretations of standards by auditors can be very individualistic to the specific standard and its text.

 

Your range of queries is admirable and welcome but also suggests you might be recommended to additionally consider approaching a consultant or look for a relevant training option (latter probably cheaper but not in time units maybe ).

 

This is only a "gut feeling" since I have never used AIB, ie an opinion acquired mainly from this forum but i think that AIB is on a considerably different expectation level as compared to, for example, the GFSI "approved" standards. Specifically, a much lower level. The point is that something like "microbial control program" may, with respect to exhaustiveness/depth, require (a) one step down from food due to "packaging" (b) another step down due to the standard itself. Maybe i am completely wrong (comments welcome) but if so, some caution is advised.

 

Rgds / Charles.C

[paconmatt]

Our netting holds raw products for retail sale such as onions, shallots, avocados, potatoes, tomatoes, etc.  Our film is cut into tiny strips and woven into a net bag so it is very similar to our extruded net product. But in both processes the plastic is heated to excess of 140 degrees to make the plastic workable so this also helps to kill organisms.  The surfaces the plastic touches after being heated I have sanitized at the beginning of every shift with a mild chlorine bleach solution.  Do you think stating this in my argument and a good GMP program would be enough? 

[paconmatt]

Avila,

what do you mean by RTE?

[Snookie]

RTE = Ready to eat.

[Snookie]

Our netting holds raw products for retail sale such as onions, shallots, avocados, potatoes, tomatoes, etc.  Our film is cut into tiny strips and woven into a net bag so it is very similar to our extruded net product. But in both processes the plastic is heated to excess of 140 degrees to make the plastic workable so this also helps to kill organisms.  The surfaces the plastic touches after being heated I have sanitized at the beginning of every shift with a mild chlorine bleach solution.  Do you think stating this in my argument and a good GMP program would be enough? 

 

The containers manufactured at our facility are subjected to temperatures ranging from 180 degrees F to 1300 degrees F.  Still since they are food contact surfaces for ready to eat, we still do some micro testing to confirm that the process is working. 

 

Since we are not intimate with your process it is really hard to give you an answer as no one wants to give the wrong answer.

 

 

Dear paconmatt,

 

Your range of queries is admirable and welcome but also suggests you might be recommended to additionally consider approaching a consultant or look for a relevant training option (latter probably cheaper but not in time units maybe ).

 

Rgds / Charles.C

 

Charles, IMHO usually gives very good advice and this one I believe is very sound.  Since your so new to these requirements and it appears your company is as well.  This could be money very well spent to have a professional come in and evaluate your processes and advise you on how best to meet the standard.

Edited by Snookie, 28 May 2014 - 09:24 PM.

[CMHeywood]

If you state that it is not needed, you need to prove it:  Do you do any swabbing to prove you don't have any contamination in materials or machines?   Can you prove that your suppliers are sending you "clean" materials.  Can you prove that you are adequately cleaning and/or sanitizing machines?  Can you prove that your employees are washing hands, wearing clean clothes, etc.

[ncwingnut]

We have done the AIB audits for over 15 years.  This year, we went to the "inspection only" format, since we also do SQF certification.  Since the AIB audit and SQF are along the same lines (SQF just incorporates more paperwork), we decided to go the inspection only route, to see where our weak points were in preparation for SQF.

 

Anyway.....

 

As far as Micro control, we do drain swabs once a month.  There are 6 drains in 5 diffent rooms, Plus we did one non-food contact (typically the outside of the mixing tank) and one control sample.  We have never done any food contact testing. This has always satisfied the AIB requirement.

 

Any product micro testing is customer specific - we don't do product micro testing unless the customer requires it.

 

Now, all that being said, since January we have changed the program to where I have over 153 non-food contact surfaces I test via ATP.  I do an average of 20/month out of that 152 for indicators.  Then I send 6 a month out for 3rd party testing for salmonella and listeria.  This change came about due to the changes coming with FSMA - we decided to be proactive and up our testing game.  This also works as sanitation validation.

[Charles.C]

Dear ncwingnut,

 

Thks for post. Good to hear something from the battlefields.

 

I deduce from yr post that AIB do not expect to see any product micro.testing at all. Frankly I find this almost unbelievable.

 

What kind of food are you producing ?

 

Apologies my ignorance but Is it apparent from the textual standard that this zero expectation exists ?

 

Rgds / Charles.C

[paconmatt]

Charles,

That's the thing.  We don't produce food of any sort.  All we manufacture is extruded net and knitted net bags that people put vegetables (and other things) in for sale.  None of the packaging we produce is even considered RTE ( ready to eat).  So this is why I am posing this question because I'm not sure if the inspector will realize we don't need a microbial control program given what we produce.

[ncwingnut]

Dear ncwingnut,

 

Thks for post. Good to hear something from the battlefields.

 

I deduce from yr post that AIB do not expect to see any product micro.testing at all. Frankly I find this almost unbelievable.

 

What kind of food are you producing ?

 

Apologies my ignorance but Is it apparent from the textual standard that this zero expectation exists ?

 

Rgds / Charles.C

 

 

We produce food flavorings and extracts, both liquid and powder.  All of our ingredients come in already pre-processed and micro tested from the vendors.  We are not required to do any micro testing on product, unless it's a customer requirement.  We don't do either food contact surfaces or finished product.

 

This has never been an issue for an FDA audit, SQF or AIB.

[Dharmadi Sadeli Putra]

Dear Ncningwut,

May i know what kind of production activities at your plant?

Do you think there's no possibility of microbial contamination during production at your plant even your ingredients already micro tested?

Rgds,

Avila

[ncwingnut]

Dear Ncningwut,

May i know what kind of production activities at your plant?

Do you think there's no possibility of microbial contamination during production at your plant even your ingredients already micro tested?

Rgds,

Avila

 

We produce food flavorings - liquids and extracts.  I did not say there is no possibility of micro contamination - all I stated was how we do our process.  There is always the threat of contamination, no matter where you are.  We do not have micro testing of finished product as part of our process, unless it's requested by the customer.  We do diligent invironmental testing and haven't had any issues thus far.  We've come a far cry further than just the drain swabbing we were doing for the past 10+ years before I started this position.

[Charles.C]

Dear ncwingnut,

 

I think maybe Avila was asking what you are actually doing ? eg just blending, pelletizing, bottling, packaging, or ?

 

Obviously this is related to the RA, eg in the context of product open to the environment, closed systems, manual interaction, etc

 

Rgds / Charles.C

[ncwingnut]

Dear ncwingnut,

 

I think maybe Avila was asking what you are actually doing ? eg just blending, pelletizing, bottling, packaging, or ?

 

Obviously this is related to the RA, eg in the context of product open to the environment, closed systems, manual interaction, etc

 

Rgds / Charles.C

 

Charles,

 

We do compounding of ingredients to make a formula - take anywhere from 2 to (we have one flavor that has) 57 ingredients, compound them, and end up with a finished product flavor.  We then package them by hand, palletize and ship.

 

We have no closed-systems - everything is mixed in stainless steel containers with a cover.  

[Dharmadi Sadeli Putra]

Dear ncwingnut,

 

I think maybe Avila was asking what you are actually doing ? eg just blending, pelletizing, bottling, packaging, or ?

 

Obviously this is related to the RA, eg in the context of product open to the environment, closed systems, manual interaction, etc

 

Rgds / Charles.C

 

Charles,

 

We do compounding of ingredients to make a formula - take anywhere from 2 to (we have one flavor that has) 57 ingredients, compound them, and end up with a finished product flavor.  We then package them by hand, palletize and ship.

 

We have no closed-systems - everything is mixed in stainless steel containers with a cover.  

Dear Ncwingnut,

Have you ever checked your finished products for mould, bacteria that may be survived after several production steps as listed above?

[ncwingnut]

Dear Ncwingnut,

Have you ever checked your finished products for mould, bacteria that may be survived after several production steps as listed above?

 

Only at customer request.