16 replies to this topic

[MmeMuffin]

Hi everyone, 
I'm back with another question   

We have a dry milling operation (oats- oatmeal, flour, bran) that I am trying to get SQF certified. Currently we don't do anything in terms of microbial testing. The previous thought process was: grain is low risk to begin with and we don't introduce water or anything that would encourage growth so it isn't necessary.

I am wanting to introduce SOME kind of testing to appease an auditor and show everything is going as planned, and that we are proactive about catching any problems.

Should I send samples off to an independent lab (as we currently don't have much in terms of a lab- we only do ELISA testing for gluten) to test for salmonella, mold, yeast, clostridium, e.coli, etc- anything we can? Though this isn't very proactive, if it comes back with non-significant numbers, would that satisfy an auditor or would they rather see a trend over the year (quarterly, monthly?, etc)... if we are having to do it frequently, are there a select few tests that we should focus on to save costs? 

A major concern of mine is contamination from plant workers, or if (heaven forbid) we get a bird or other pest in the plant to contaminate things. The pests we can monitor using our pest control plan (?), but should we do some swabs on workers' hands to validate hygiene procedures in addition to/in place of product testing?  

Any other options I should consider? ATP? Other rapid tests? 

Thanks in advance!

[fgjuadi]

It sounds like what you're looking for is an environmental monitoring program (contamination from the plant) . 

I'd recommend searching this forum and google for that phrase - it can be daunting, but there are a lot of good how to powerpoints out there. 

It is proactive - you swab drains, tires, feet, equipment frames, leaks for salmonella and listeria, send to a 3rd party lab.  If you find something, stop foot traffic/use, clean it, and then swab, until your swabs come back clean.  Results take some time, but are not tied to a lot/batch of product.   Trending is important. so you can respond with increased cleaning, foot traffic control,. etc.

 

You can also do finished product testing, but that's a separate program.  Micro testing for finished product on flour probably isn't productive, but you could try Salmonella and e coli 

That's when you take finished product, test it for your specifications (y&m, e coli, coliform - whatever your spec sheet says).  If it's out of specification, you don't ship it, you destroy it.   If you've already shipped it...recall.  Making this a condition of release is common but problematic because you have to keep finished goods sitting around for a few days.  If your customers are other factories, not retail, they will expect these results on a COA.  Counts are typically high on flour as it is not RTE & doesn't usually go through a kill step, but for some reason consumers love to eat raw stuff.

 

You can do pre-operational inspections as well - these are ATP swabs .   Basically you swab the food contact surfaces, and if the number is out of range, you clean again until the swab is in range.  You set the range yourself via trial and error.   You can take micro pre-operational tests as well if you want to, but you would have to wait for the results before releasing product.  If you are doing finished product testing you'll have results around the same time

 

For flour - others on here are more knowledgeable (I only have rice and some soy  flour experience) - but I'd say focus on PRP Programs (pre-operational checks, Environmental monitoring program), not finished product testing.  Here's a nifty link on micro in flour - http://www.ardentmil...White_Paper.pdf

Edited by magenta_majors, 29 December 2014 - 09:43 PM.

[RG3]

Grains: Biological- VP; Salmonella SP; Clostridium botulinum, C. perfringens, Bacillus cereus  Chemical - Wheat, Soy, Pesticides, Aflatoxins

I would say the same for flour as far as biological goes. I wouldn't test the Spore Forming just go for Salmonella. You shouldn't have trouble since you have low to no water activity.

 

I wouldn't test every batch if you're already receiving a COA or LoG. I would validate (Charles C.favorite word) the results with a 3rd party lab quarterly. Perhaps for now with more frequency to establish more history.

[Mr. Incognito]

In our HACCP plans we only address Salmonella and we state that our product isn't made ready to eat as per the product spec sheet and intended use statement.  We say that the product is to be put though a micro kill cooking process before it's eaten.

 

We do have our environmental monitoring program set as well to look for salmonella which we've never had any hits on.

 

We are FSSC not SQF but even our FSSC inspector, who is also an SQF inspector, basically said that because we were a flour mill that he didn't expect to see any more than that for micro concerns.

[MmeMuffin]

In our HACCP plans we only address Salmonella and we state that our product isn't made ready to eat as per the product spec sheet and intended use statement.  We say that the product is to be put though a micro kill cooking process before it's eaten.

 

We do have our environmental monitoring program set as well to look for salmonella which we've never had any hits on.

 

We are FSSC not SQF but even our FSSC inspector, who is also an SQF inspector, basically said that because we were a flour mill that he didn't expect to see any more than that for micro concerns.

Great to hear! Thank you! We do have that the product is not ready to eat in our documents. 

Everyone's comments have made me feel much more confident.  I should have mentioned that the owners of the company grow the product we use, so we don't get a CoA or anything when we receive the grain (we would have to generate it if we did!).

I will be pitching that when we receive the grain from the farmer we test for salmonella, e.coli, clostridium botulinum, c. perfringens, bacillus cereus, aflatoxin and vomitoxin (DON). Since we have some products that don't receive any heat treatment at all, this would let us catch if there were for some reason high enough concentrations to cause illness already on the grain. We wouldn't process the grain until receiving results.... if there are high amounts then maybe further testing after we run the seed through the cleaners? Or maybe further down the line. 
When we expand in the next couple of years to include other farmers, I'll add in testing for wheat, soy, pesticides, etc... but right now we are so stringent those aren't a concern.

Then I'll look into whether we can do an in house test for salmonella (to reduce turn around time) on the flour.... and I'm going to shoot for ATP tests if I can convince those who guard the money that it'd be worth it   


 

[Mr. Incognito]

We do send out samples for aerobic plate count, coliform, and yeast / mold testing but the only salmonella testing we do is on our environmentals. 

 

Good luck! Sounds like you have a good plan moving forward.

 

My only concern for you moving forward is that you are receiving raw materials from yourself without treating it like a supplier.  At the pasta plant I worked at when we received in a load of flour from our sister plant we had a COA from them and all documentation as if they were an outside company.  I'm not sure if SQF is going to be happy with how you do that.  Someone with more SQF experience can weigh in on that though.

[MmeMuffin]

It sounds like what you're looking for is an environmental monitoring program (contamination from the plant) . 

I'd recommend searching this forum and google for that phrase - it can be daunting, but there are a lot of good how to powerpoints out there. 

It is proactive - you swab drains, tires, feet, equipment frames, leaks for salmonella and listeria, send to a 3rd party lab.  If you find something, stop foot traffic/use, clean it, and then swab, until your swabs come back clean.  Results take some time, but are not tied to a lot/batch of product.   Trending is important. so you can respond with increased cleaning, foot traffic control,. etc.

 

You can also do finished product testing, but that's a separate program.  Micro testing for finished product on flour probably isn't productive, but you could try Salmonella and e coli 

That's when you take finished product, test it for your specifications (y&m, e coli, coliform - whatever your spec sheet says).  If it's out of specification, you don't ship it, you destroy it.   If you've already shipped it...recall.  Making this a condition of release is common but problematic because you have to keep finished goods sitting around for a few days.  If your customers are other factories, not retail, they will expect these results on a COA.  Counts are typically high on flour as it is not RTE & doesn't usually go through a kill step, but for some reason consumers love to eat raw stuff.

 

You can do pre-operational inspections as well - these are ATP swabs .   Basically you swab the food contact surfaces, and if the number is out of range, you clean again until the swab is in range.  You set the range yourself via trial and error.   You can take micro pre-operational tests as well if you want to, but you would have to wait for the results before releasing product.  If you are doing finished product testing you'll have results around the same time

 

For flour - others on here are more knowledgeable (I only have rice and some soy  flour experience) - but I'd say focus on PRP Programs (pre-operational checks, Environmental monitoring program), not finished product testing.  Here's a nifty link on micro in flour - http://www.ardentmil...White_Paper.pdf

Thank you for that white paper link! This will help with discussions to allocate for this in the budget. We do not produce ready-to-eat foods at the moment, but still, some of our products are popular with the raw food crowd, as well. 

[MmeMuffin]

We do send out samples for aerobic plate count, coliform, and yeast / mold testing but the only salmonella testing we do is on our environmentals. 

 

Good luck! Sounds like you have a good plan moving forward.

 

My only concern for you moving forward is that you are receiving raw materials from yourself without treating it like a supplier.  At the pasta plant I worked at when we received in a load of flour from our sister plant we had a COA from them and all documentation as if they were an outside company.  I'm not sure if SQF is going to be happy with how you do that.  Someone with more SQF experience can weigh in on that though.

Yes, as soon as I typed that I realized that we should probably generate the documentation just to "C OUR A's",  ... I just hadn't thought of it before! When I started at this company, they hardly had anything in the way of documenting production, no written SOPs or any sort of employee training -- so it's been a long process. I'll add that to my list :)

[RG3]

My only concern for you moving forward is that you are receiving raw materials from yourself without treating it like a supplier.  At the pasta plant I worked at when we received in a load of flour from our sister plant we had a COA from them and all documentation as if they were an outside company.  I'm not sure if SQF is going to be happy with how you do that.  Someone with more SQF experience can weigh in on that though.

My answer to this is yes. We own our own farms so it's considered raw material once it arrives here on our docks from a supplier even though it is us. They do not get any special treatment. They still receive supplier complaints from me. They need to be treated as a supplier. Our auditor asked to see some GFSI certificates from the farms (or an audit I had done on them) some product specification sheets, and looked to see if they were on our approved supplier list.

Edited by RG3, 31 December 2014 - 06:56 PM.

[Mr. Incognito]

That's what I thought.


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[Charles.C]

Dear Mr.Inc,

 

We do have our environmental monitoring program set as well to look for salmonella which we've never had any hits on

 

 

It may mean that one's sampling / analytical set-up is inadequate to detect it ?

 

As far as micro-testing goes, it would seem logical to me (but maybe not a FSSC/ SQF inspector) to include testing sufficient to show compliance with one's product specification. The latter would, IMO, minimally be based on a hazard analysis from a safety POV.

 

Does not necessarily demand every micro-item have the same frequency of testing of course.

 

The aspect of a projected onward heat treatment is IMO a valid input to a risk assessment but, from a regulatory POV, may nonetheless be irrelevant, eg adulteration.

 

I wondered if the OP has actually ventured into HACCP/hazard analysis yet ? just curious.

 

Rgds / Charles.C

[Mr. Incognito]

Dear Mr.Inc,

 

 

It may mean that one's sampling / analytical set-up is inadequate to detect it ?

 

 

 

Rgds / Charles.C

 

One could but we check monthly in multiple places where it would show up if we had a problem.

[Trace Analytics]

Hello-

 

If you use compressed air in any of your processes, there is a potential for microbiological contamination from the air.

[Boykie]

In our HACCP plans we only address Salmonella and we state that our product isn't made ready to eat as per the product spec sheet and intended use statement.  We say that the product is to be put though a micro kill cooking process before it's eaten.

 

We do have our environmental monitoring program set as well to look for salmonella which we've never had any hits on.

 

We are FSSC not SQF but even our FSSC inspector, who is also an SQF inspector, basically said that because we were a flour mill that he didn't expect to see any more than that for micro concerns.

For validation of the micro kill cooking process, what would you test for?

TVC?, Salmonella?, BC?

[Scampi]

Please read the attached link and see how far and wide this recall ending up going....I understand the salmonella is for enviro monitoring....but this recall is from ecoli in raw flour

 

http://time.com/4802...-recall-e-coli/

http://www.cbc.ca/ne...mills-1.4154644

 

Remember please, manure is used on these fields and if it wasn't processed/old enough this is the end result

[Scampi]

And another one

www.fda.gov/Food/RecallsOutbreaksEmergencies/Outbreaks/ucm504192.htm

[Scampi]

http://ucfoodsafety....iles/271162.pdf

 

Also included in the list is refrigerated cookie dough. Just because people "shouldn't eat raw dough" does not make it ok for it to be contaminated.

 

http://www.tortilla-...Alex Brandt.pdf