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Closing a non-conformance relating to a biological hazard

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joelchenda

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Posted 19 November 2014 - 01:07 PM

Auditor gives us a non-conformance as hazard identified as biological, the control measure identified as the CCP and control measure resolves around the chlorine levels and not the micro levels.

In our HACCP plan, the control parameters of this CCP is the measure of chlorine concentration [50ppm-80ppm] to reduce the biological hazards to acceptable levels. can some one assist us as how to explain this to convice the auditor.

Regards, Joel



Scampi

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Posted 19 November 2014 - 01:31 PM

Do you also do random micro checks on the product to ensure that the CCP is actually working? I would also be prepared to present pH levels of the water you're using as the chlorine's efficacy is dependant on your pH.

We have the same CCP here, but do random swabs on finished product as part of verifying the CCP. Which standard (other than HACCP) are you working within?


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joelchenda

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Posted 19 November 2014 - 03:42 PM

Hi Scampi

Thanks for the reply, we do weekly random micro tests on products, should we be specific that samples are collected for testing just after the CCPs step? On the PH levels of water and chlorine efficacy, what should be the PH range for the chlorine to be effective? We are also working within FSSC 22000 standard.



fgjuadi

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Posted 20 November 2014 - 04:13 AM

Ah, finished product testing is different.   To verify that your chlorine levels are accurate (high enough to kill , low enough to be no rinse food safe) you check the chlorine when you start up the sink, or every two hours, etc, make a log, procedure for if it is out of range, etc, .   That's if your auditor had a problem with how you monitor the chlorine.

 

To validate that the chlorine is controlling bacteria is different.  This article  explains more about it and has links to studies supporting different sanitizer (either hypochlorite or chlorine dioxide for you) but in particular give some advice about validation technique - It's more for if your auditor had a problem with how you *knew* the chlorine killed stuff. 

 

"The sanitization standard for contamination reduction of food contact surfaces is generally accepted as 99.999% (a 5-log reduction) achieved in 30 seconds (Official Detergent Sanitizer Test).[3] The sanitization standard for nonfood contact surfaces is accepted as a reduction of 99.9% (3 logs) within 30 seconds."


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Charles.C

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Posted 20 November 2014 - 12:01 PM

Dear joelchenda,

 

To give a rational reply, it's necessary to, minimally,  know (a) the product, (b) the process, © the specific hazard, (d) the specific targetted acceptable level of the hazard, (e) the typical range of levels of the hazard in the input / output.

 

I deduce the auditor was dissatisfied with yr designation of the step as a CCP ?  Specifically why ? A few possibilities might be that  the auditor considered that  -

 

(1)   yr acceptable level not appropriate ?

 

(2)  the CCP not validated ? (How do you currently validate )?

 

(3) a (fssc) problem that continuous monitoring not feasible, eg > OPRP (this particular criticism could be a debate)?

 

Or ?

 

Rgds / Charles.C.


Kind Regards,

 

Charles.C


fgjuadi

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Posted 20 November 2014 - 12:10 PM

Dear joelchenda,


 

I deduce the auditor believed the step was not a CCP ? Why ?

 

Charles.C.

Oh, I didn't even think of that.   Good call. 


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Zonneke

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Posted 20 November 2014 - 02:26 PM

Hello, in my opinion you can not have microbiology testing as a control measure, because you will never get results fast enough. The control measure on a CCP means that you are ableto make an instant decision: CCP under control: yes or no. For that reason it seems to me that chlorine levels are suitable (as long as it is validated that a certain level will result in satsifying micro results of course :-)



CMHeywood

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Posted 20 November 2014 - 06:40 PM

Checking the chlorine level verifies that you are keeping the concentration where you think it should be.  Checking the microlevel validates that your concentration level is correct for controlling the microlevel.  I would think that showing test data of the microlevel would prove to the auditor that maintaining a certain chlorine level is sufficient control.



Tony-C

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Posted 21 November 2014 - 06:06 AM

Dear joelchenda,

 

To give a rational reply, it's necessary to, minimally,  know (a) the product, (b) the process, © the specific hazard, (d) the specific targetted acceptable level of the hazard, (e) the typical range of levels of the hazard in the input / output.

 

Rgds / Charles.C.

 

Exactly, as Charles has requested please provide more information.

 

Regards,

 

Tony





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