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Advise Needed On Flour Beetles


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#1 Miss Tammy

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Posted 20 June 2014 - 02:01 PM

We are a bakery that produces fresh and frozen products as a co-packer for multiple major, national brands as well as multiple store brands.  I have been FSQ Manager since 2008.  We have had numerous customer audits, as well as 4 BRC audits.  We have done very well on all of them, including 4 "A's" from BRC.  In February we were audited by our biggest customer and FAILED!  Although we did not agree with all of his findings, we had not stopped production at all for sanitation in 6 weeks, and conceded there were issues.  This is highly unusual and was due to this same customer asking for more than double the amount of product they usually order.  The same guy came back to re-audit us and FAILED us a second time!  We just passed our BRC with an A May 1st, and worked on extra sanitation prior to his arrival.  The reason for the failure?  3 Criticals which were:

1.  A bolt had come loose from a plate on the back of a mixer jacket that had product residue under it and several small flies around it.

2.  3 flour beetles on the OUTSIDE of a sifter.  The source was located immediately, which was an area under a gasket that had not been cleaned

3.  After having 0 beetles in our tailings for months, we had gone up to 20 after the bag house was cleaned.  The amount is comming down, but he is adament that we have an infestation in our flour.  Our critical limit for beetles in tailings is 20, and I know where they are comming from, so no corrective action was taken.

 

He states that 20 is entirely to much, and we should only have 2 or 3.  When I asked what the policy was for bakeries owned by them, he replied they didn't have a written limit. 

 

Sorry for writting a book!  Just venting I guess.  My question is (finally) what should the critical limits be for flour sifter tailings, and am I wrong for disputing the outcome of this audit?  Other than the criticals, we had one major (cracked clock) and one minor. 
 



#2 Supply Chain Food Safety

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Posted 20 June 2014 - 03:06 PM

I don't agree that there should be a critical limit for tailings.  However, I do believe that you should react to spikes in insect counts.  I wouldn't make any knee jerk corrective actions.  Maybe start by approaching the flour mill to see if they have fogged, worked the rebolt sifter, cleaned trucks all on schedule.  What yo've described is common for the indusrty not an infestation.  If he only saw 3 live beatles thats good.

 

Ive only heard of critical limits on frags/filth.  The government sets a max number of insect frags you can have in your final product.  

 

Ive worked in the flour milling industry but I've never heard of a critical limit on bugs in the tailings. Its common to see bugs in the tailings of every truck load...that doen't mean the flour is infested.  At the very least I would toss it back to the mill you're being supplied and have them do an investigation/Root Cause. 



#3 Mr. Incognito

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Posted 20 June 2014 - 03:12 PM

Do you trend the amount of pests found?


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#4 Miss Tammy

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Posted 20 June 2014 - 03:59 PM

Thank you very much.  I do not feel we have a problem at all.  As I stated earlier we had cleaned out the bag house and each time we do we have a spike in beetles.  That is why I did'nt react to it.  As the sifters are part of our pre-rec program, I wanted to set a limit in order to be informed by my staff if we were starting to have a problem.  I too believe we are doing great if he only saw 3 beetles, but wanted some other opinions. 



#5 Miss Tammy

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Posted 20 June 2014 - 04:04 PM

Yes, we do trend all other pests, but this does not include flour beetles as in a bakery they are the "Nature of the beast".  We sift the tailings daily and record the amount of beetles as well as any other foreign material.  I periodicaly review this record but have not had any significant issues.  The corrective action stated on the form for foreign material or beetles exceeding 20 is to notify me immediately.  I would then do a root cause and CA if needed.



#6 Snookie

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Posted 20 June 2014 - 04:27 PM

I have many times had an auditor come into our facility who is not experienced with the type of product we are making and believe we had problems because they did not understand.  In the drive to food safety it is all to easy for auditors feel like they are the lone guards of protection and the rest of us are suspect. 

 

I am not experienced in bakery....that being said, it sounds like the auditor does not understand the what the true dangers are and if this is not an abnormal amount, you should dispute the findings.  Food needs to be safe, but if we let craziness rule the day, there won't be enough food that is "considered" safe and there are going to be a lot of hungry people, especially as this so called " safe" food is going to cost a fortune. 


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#7 Miss Tammy

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Posted 20 June 2014 - 04:40 PM

This auditor is VERY experienced in our industry and as an auditor.  That is what makes it so frustrating, and made me doubt my conclusions.  Also why I reached out to my very knowledgable QA friends on this forum to validate that what I believe is correct.  We have contacted the owner and CEO of our company and he is looking into disputing the findings.  Failing 2 audits in a row is absolutely unacceptable to us when it in no way reflects the true picture.



#8 Snookie

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Posted 20 June 2014 - 07:20 PM

This auditor is VERY experienced in our industry and as an auditor.  That is what makes it so frustrating, and made me doubt my conclusions.  Also why I reached out to my very knowledgable QA friends on this forum to validate that what I believe is correct.  We have contacted the owner and CEO of our company and he is looking into disputing the findings.  Failing 2 audits in a row is absolutely unacceptable to us when it in no way reflects the true picture.

 

 

Sorry to hear he is so experienced, had hoped that might be part of the issue.  I would keep monitoring the topic as other bakery and flour people may respond.  Good luck and let us know how it goes. 


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#9 Hareesh

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Posted 21 June 2014 - 03:50 AM

Even though experienced, if this auditor audits bakeries it seems that his company will not have any bakeries to supply them. I liked his suggestion to setting critical limit of beetles to 2 or 3. Next time when he comes he can cite that and make the company fail the audit.  


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#10 fgjuadi

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Posted 23 June 2014 - 11:09 AM

We are a bakery that produces fresh and frozen products as a co-packer for multiple major, national brands as well as multiple store brands.  I have been FSQ Manager since 2008.  We have had numerous customer audits, as well as 4 BRC audits.  We have done very well on all of them, including 4 "A's" from BRC.  In February we were audited by our biggest customer and FAILED!  Although we did not agree with all of his findings, we had not stopped production at all for sanitation in 6 weeks, and conceded there were issues.  This is highly unusual and was due to this same customer asking for more than double the amount of product they usually order.  The same guy came back to re-audit us and FAILED us a second time!  We just passed our BRC with an A May 1st, and worked on extra sanitation prior to his arrival.  The reason for the failure?  3 Criticals which were:

1.  A bolt had come loose from a plate on the back of a mixer jacket that had product residue under it and several small flies around it.

2.  3 flour beetles on the OUTSIDE of a sifter.  The source was located immediately, which was an area under a gasket that had not been cleaned

3.  After having 0 beetles in our tailings for months, we had gone up to 20 after the bag house was cleaned.  The amount is comming down, but he is adament that we have an infestation in our flour.  Our critical limit for beetles in tailings is 20, and I know where they are comming from, so no corrective action was taken.

 

He states that 20 is entirely to much, and we should only have 2 or 3.  When I asked what the policy was for bakeries owned by them, he replied they didn't have a written limit. 

 

Sorry for writting a book!  Just venting I guess.  My question is (finally) what should the critical limits be for flour sifter tailings, and am I wrong for disputing the outcome of this audit?  Other than the criticals, we had one major (cracked clock) and one minor. 
 

 

 

I hate to be a debbie downer here, but it kind of seems like you need to clean more often.

 

6 weeks?  That's a really long time for flour to start decomposing in the tight spaces.

 

I've never worked in a bakery, but in a flour mill even our racks were cleaned at this frequency, and everything expect overheads in the processing area was cleaned way more often.  Baghouses were on quarterly. (As a side note, our staff spoke with heavy accents, and the first time they told me there was a problem with one, I was wondering why on earth maintenance spent a day on the roof listening to Bauhaus.) 

 

 

 

Yes, we do trend all other pests, but this does not include flour beetles as in a bakery they are the "Nature of the beast". 

Funny, that's why I think they should be monitored - a lot.   If I ever found confused flour beetles or Indian meal moths in my mill it was full freak out mode because they loooove our product.  If they;re coming form the baghouse Id suggest going up there with maintenance and checking it out to make sure they can't get inside. 

 

20 CFB next to a sifter? :o  My action limits at the mill were 2-3 in the warehousing areas,  Maybe baking is a different animal, or maybe you could look at the baghouse cleaning procedure to minimize contamination risk


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#11 jkoratich712

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Posted 23 June 2014 - 02:41 PM

I have worked in multiple bakeries, and our standard was >5 flour beetles in the tailings would result in a recheck of tailings in 30-60 minutes to see if that amount increased or decreased. We would see 'pockets' form in our silo's due to the change in weather and until we cleaned them we would start to see some beetles in the tailings. After the 1st recheck, if the quantity increased we would then go and inspect the silo and contact the supplier. Usually (99.9% of the time) the next check would show no beetles and we would just document the findings. This also satisfied auditors (AIB and SQF) and there never seemed to be an issue.

 

I also can relate to the not stopping production in weeks for sanitation due to orders and such. If you ever figure out a solution around that, let me know!



#12 Miss Tammy

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Posted 23 June 2014 - 03:00 PM

Even though experienced, if this auditor audits bakeries it seems that his company will not have any bakeries to supply them. I liked his suggestion to setting critical limit of beetles to 2 or 3. Next time when he comes he can cite that and make the company fail the audit.  

I would very much like to visit one of the bakeries owned by his company.  I find it hard to believe there are no beetles in these facilities.  I think he may be unaware of the reality of the amounts.  The managers there may be like me and not feel there is even a problem if there is not a policy in place for action limits.  Thanks for your input!



#13 Miss Tammy

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Posted 23 June 2014 - 03:08 PM

I have worked in multiple bakeries, and our standard was >5 flour beetles in the tailings would result in a recheck of tailings in 30-60 minutes to see if that amount increased or decreased. We would see 'pockets' form in our silo's due to the change in weather and until we cleaned them we would start to see some beetles in the tailings. After the 1st recheck, if the quantity increased we would then go and inspect the silo and contact the supplier. Usually (99.9% of the time) the next check would show no beetles and we would just document the findings. This also satisfied auditors (AIB and SQF) and there never seemed to be an issue.

 

I also can relate to the not stopping production in weeks for sanitation due to orders and such. If you ever figure out a solution around that, let me know!

We had zero beetles for months until the bag house was cleaned.  This happens every year, and they go back down at the end of the summer.  This is why I was not alarmed.  I felt as if I knew the reason, and they are already coming down.  Even though I explained this to him and showed him records to verify, he is still adament that our flour is infested and the silos need to be cleaned out.  Thanks for the advice.  I just wanted some validation that what we are doing is not a critical food safety issue.  The way I see it, it is not a food safety issue at all.  What are sifters for anyway?!



#14 CapjemMary

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Posted 24 June 2014 - 03:22 PM

Hi Tammy! I'm sorry to hear about this situation. It seems like your team is being very cooperative. Section 3 of the BRC manual gives instructions for appeals..."must be made in writing within 7 days of the receipt of the certification decision".

 

Disputing isn't as uncommon as you may think. But I would definelty only proceed if you are very secure in your opinion. Maybe check with the flour supplier first and talk with other local manufaturers who have undergone similiar situations, even recently to see if it is a regional thing. I.E. Do your due diligence before you unleash on the auditor. They can be, well...fiesty. :silly:

 

I work with a certification assistance firm and we automaticcaly include this kind of support in our services with our clients since you never know what they're going to throw your way.

 

Even though you're already in the throws of it all, we still may be able to assist if you'd like to chat.

 

Good luck!

 

MG






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