12 replies to this topic

[PaulVancouver]

We're a small scale food manufacturer and in the process of getting SQF certified.  We've completed our Level 2 audit and passed, however we're having a problem closing out one of our Non-Conformities.  The auditor is demanding a Certificate of Analysis for the Raw, Fresh Pork we receive.  We're federally registered and the Canadian Food Inspection Agency does not require a certificate of analysis.  Canada also does not require Trich treatment or testing.  I've talked with 2 consultants, 2 laboratories, 4 CFIA inspectors and the QA department of the largest Pork processor in Canada, all of them are completely at a loss as to what could be tested for in raw fresh pork.

 

Would anyone here have gone through a similar situation?  What did you do to satisfy your auditor?

[RG3]

I would say S.aureus, Salmonella, Campylobacter, L.mono, and maybe C.perfringens would be a good start. I don't see why you wouldn't test. How can you demonstrate safe food without testing? If your facility becomes contaminated, how would you be able to prove that it didn't come from your facility and that it came from a raw material without establishing some sort of history? Are you blindly excepting any/all ingredients without proof that they are "contaminate free".

[RG3]

A parasite normally found in pork is Trichinae.

 

Some other honorable mentions that may be worth testing for Escherichia coli 0157, Yersinia enterocolitica.

 

What is your justification for not needing a COA on a major raw ingredient?

[PaulVancouver]

Thanks RG3... We require Letters of Guarantee from all of our suppliers which have extensive information about the wholesomeness of the food they are delivering.  I suppose in other facilities your points would be correct, but we don't have any kill steps as our product is produced and shipped raw/frozen.  For example if we were cooking the product, we could rely on testing post kill step.

 

As for a justification, I don't have one.  If I were king of the world, I would have one.  I've gone to several suppliers for this and all of them are refusing to share any COAs and our labs are at a loss as to what they should test for because there is a high probability of a positive result, but that would still not pose any risk to humans because a kill step later would eliminate it.

[PaulVancouver]

Thanks RG3... We require Letters of Guarantee from all of our suppliers which have extensive information about the wholesomeness of the food they are delivering.  I suppose in other facilities your points would be correct, but we don't have any kill steps as our product is produced and shipped raw/frozen.  For example if we were cooking the product, we could rely on testing post kill step.

 

As for a justification, I don't have one.  If I were king of the world, I would have one.  I've gone to several suppliers for this and all of them are refusing to share any COAs and our labs are at a loss as to what they should test for because there is a high probability of a positive result, but that would still not pose any risk to humans because a kill step later would eliminate it.

[fgjuadi]

You test for the specification on the product spec sheet.  It should list micro limits. 

[Snookie]

Pork is not my area of expertise, so my advice might not be correct....now that we got that big caveat out of the way:

 

Can your supplier create a simple COC that says product meets all applicable regulations etc. (some word crafting is necessary) and is safe for human consumption?

 

Or in the case of produce where we don't do a lot of lab testing, we satisfied the requirement by simple things in house, a brix test, a pressure test or we took samples which were visually inspected or subject to organoleptic testing. 

[Mike Green]

In the Uk the British Meat Processors Asociation do have a micro limit in their specification for incoming raw pork which is chilled/frozen

 

 

6.2.4 The microbiological condition of the incoming pork shall be monitored to a 

risk assessed schedule and details recorded in order to meet the following 

standard:

TVC Target <1 x 10⁴ CFU per gram

Upper Limit <1 x 10⁶ CFU per gram

 

 

Not sure if there is a Canadian equivalent (perhaps not!)

 

Mike

 

 

 

 

[PaulVancouver]

I had never heard of a Certificate of Compliance Snookie.  That's some awesome advice.  I'll see if our supplier would do that.

 

Magenta_majors, as this is a single ingredient cut of meat, there actually is very little information required on the spec sheet.  I suppose the closest thing that could be checked for is that it's 75% lean.  There are no micro limits on the spec sheet.  Again, probably because it's not a federal requirement.

 

Awesome Mike!  That looks like a very good guide as well!  If a COC won't work, we'll just have to do validation using UK Meat Processor standards.  

 

Thanks to all of you!  You've managed to help out a lot!  Hope I can repay the favour one day.

[Snookie]

BTW   . 

[RG3]

Thanks RG3... We require Letters of Guarantee from all of our suppliers which have extensive information about the wholesomeness of the food they are delivering.  I suppose in other facilities your points would be correct, but we don't have any kill steps as our product is produced and shipped raw/frozen.  For example if we were cooking the product, we could rely on testing post kill step.

 

As for a justification, I don't have one.  If I were king of the world, I would have one.  I've gone to several suppliers for this and all of them are refusing to share any COAs and our labs are at a loss as to what they should test for because there is a high probability of a positive result, but that would still not pose any risk to humans because a kill step later would eliminate it.

 

I'm not sure about Canada, but in the US you would still be liable because there is an inherited risk. The best example I can give is when people got sick from eating raw Nestlé cookie dough. This is why when you do your HACCP you have to take into account the population that consumes your product and all the possibilities. You can be RTC and have the label that says cook before consumption as a PRP but does everybody follow the cooking instruction to the T. Below is from the FDA.

 

"As of July 10, 2009, CDC reported that 76 people from 31 states have been infected with the outbreak strain of E. coli O157:H7. As of that date, 35 people had been hospitalized, including 11 with a serious complication called hemolytic uremic syndrome. No one has died."

 

"On June 19, 2009, the Food and Drug Administration (FDA) and the Centers for Disease Control and Prevention (CDC) warned consumers not to eat any varieties of prepackaged Nestlé Toll House refrigerated cookie dough due to risk of contamination with E. coli O157:H7 (a bacterium that causes foodborne illness).

FDA had found E. coli in a sample of the cookie dough, following reports that people had become sick after eating the product."

 

CoC I find more acceptable for primary packaging items.

[RG3]

Sorry, where are my manners   

[Charles.C]

Dear All,

 

The practical reality IMEX in the ( apparently non-USA, non-UK, non-?? sueing world) is that items like COAs, COCs are a pipedream for many items / many suppliers. And such a lack can even be validated if one delves into the pronouncements of some Certification aficionados (a thread exists here related to this topic).

 

Just as an example, try getting a COA from a ship ? or a COA from an intermediate supplier buying raw, fresh products from a “market” ?

 

Microbiological analyses (and especially for many pathogens) are simply time-impossible when accepting/rejecting truck loads of fresh, incoming raw material destined for immediate processing. The best one can do is random sampling/checking of time-accessible parameters and implement retrospective activities for the others.

 

This is why IMEX an absolutely minimal requirement for a manufacturer to receive any input material is that a mutually agreed specification exists between buyer and the immediately preceding seller.

And tomorrow the Production Manager will send a worker to the nearest Department store to purchase a random jar of spices because someone forgot to check the stock balance. Another “exception” to document in the X-file which illustrates an unhighlighted objective for evaluating “Continuous Improvement”.

 

There are perhaps analogies to the current parallel thread comparing mock recalls to the real thing.

 

My 2 pennies worth.

 

Rgds / Charles.C