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Low Water Activity Foods and Micro


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AJ1795

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Posted 05 February 2015 - 07:48 PM

Hello Everyone,

 

I am meeting management resistance in regards to microbiological testing.  The constant refrain: "the water activity in our products/ingredients is too low to support the growth of anything."  Can someone back me up here (perhaps a good article or something) that testing on some level is still necessary? Thanks!



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Posted 05 February 2015 - 08:05 PM

Some additional information would be helpful.  Are we talking environmental, raw or finished product?  What type of product are we talking about?


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AJ1795

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Posted 05 February 2015 - 08:09 PM

Starch bed samples (I have a previous post on this, if you want more in depth information) but I also hear the same for finished product (confectionery aw = 0.6).



Quality Ben

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Posted 06 February 2015 - 08:31 AM

Water activity is not the be all and end all.

Remiind your employers of incidents such as the following contamination scares - 

2008 - Wheat flour contaminated with naturally-occurring pyrrolidizine alkaloids is thought to be the cause of 38 cases of hepatic veno-occlusive disease including 4 deaths in Afghanistan

2011 - German E. coli O104:H4 outbreak was caused by EHEC O104:H4 contaminated fenugreek seeds imported from Egypt in 2009 and 2010.

2012, August - September - Multiple American Licorice Company black licorice products recalled due to high lead levels in the products. Consuming a bag of product could give children lead levels as high as 13.2 micrograms/daily limit, double the amount regulators consider actionable.

 

But that said - you are working with a very low risk product so you would not need the rigorous testing schedule like a more high risk product.

Maybe determine top 3 possible contaminants based on investigation into where it comes from / possible contaminants etc etc and test for them once evry three months (or based on risk) to show due care?



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fgjuadi

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Posted 06 February 2015 - 03:47 PM

Ugh, I hear this *all the time* becuase my product is chocolate -

 

http://www.telegraph...-chocolate.html

 

If you can give us your product it would be easier to come up with examples of micro risk.


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Posted 06 February 2015 - 04:02 PM

Even in case you are right and there is no possibility of microbiological growth -> there is no guarantee that the product was not contaminated before! Moreover it can be contaminated during processing steps!

Just think about the PIGS principle!

Presence of Hazards

Introduction of Hazards

Growth of hazards

Survival of Hazards

 

Maybe G might not be of interest, but are you confident, that you don´t have any problems with the others?

So maybe at least some testing on raw material should be made.

 

Actually I am shocked that you don´t do any testing O.O

But maybe it´s because I am really sensitive to microbiological hazards due to my products (baby food)......



AJ1795

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Posted 06 February 2015 - 04:02 PM

Ugh, I hear this *all the time* becuase my product is chocolate -

 

http://www.telegraph...-chocolate.html

 

If you can give us your product it would be easier to come up with examples of micro risk.

 

We are one of only a handful of companies that make this specific product, so for the sake of anonymity, I'd rather not say (I wish I could but I like my job--most of the time!).  It's basically a fat-free nougat product.  We have a kill step near the beginning of the process but the product is then coated in starch.  It is low risk, unfortunately, others seem to believe it is no risk.  Historically, there has never been an issue with the product, or others like it, which only lends weight to the belief that I am being overly cautious and wasting time and money on testing  :thumbdown:



AJ1795

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Posted 06 February 2015 - 04:07 PM

Even in case you are right and there is no possibility of microbiological growth -> there is no guarantee that the product was not contaminated before! Moreover it can be contaminated during processing steps!

Just think about the PIGS principle!

Presence of Hazards

Introduction of Hazards

Growth of hazards

Survival of Hazards

 

Maybe G might not be of interest, but are you confident, that you don´t have any problems with the others?

So maybe at least some testing on raw material should be made.

 

Actually I am shocked that you don´t do any testing O.O

But maybe it´s because I am really sensitive to microbiological hazards due to my products (baby food)......

 

 

Exactly the point I am trying to drive home-- survival if not growth!  We do test finished product (surprisingly, only one customer requests this with every order so it is only done when they order-- ~1 per month) and have not seen any issues.  It's a small company, just getting started with auditing and the like, so I'm trying to start more EM, etc. and move towards best practices, even if it does sometimes seem like overkill. 



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Posted 06 February 2015 - 04:08 PM

  We have a kill step near the beginning of the process but the product is then coated in starch.  It is low risk, unfortunately, others seem to believe it is no risk.  Historically, there has never been an issue with the product, or others like it, which only lends weight to the belief that I am being overly cautious and wasting time and money on testing  :thumbdown:

Do you test the starch? Because it could recontaminate your product.

Historically... you mean no complaints? Because without testing its hard to say that there where never problems.

 

For Verification... do you test samples after and before heating step? Every 3 month or something (depending on risk assessment)?



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Posted 06 February 2015 - 04:10 PM

ahh you just answered one question :)

 

Do you feel confident about the validation of your heating step?



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Posted 06 February 2015 - 04:10 PM

Do you test the starch? Because it could recontaminate your product.

Historically... you mean no complaints? Because without testing its hard to say that there where never problems.

 

For Verification... do you test samples after and before heating step? Every 3 month or something (depending on risk assessment)?

 

More frequent starch testing is what I am trying to get resources for right now.  Like I stated before, we do test finished product randomly, so *technically* some of the starch is being tested. 



AJ1795

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Posted 06 February 2015 - 04:14 PM

ahh you just answered one question :)

 

Do you feel confident about the validation of your heating step?

 

 

Our kill step heats to over 110C and holds for several minutes, so I am not worried about initial contamination.  My concern is with the post-cooking introduction of contamination (e.g. the starch bed!).



SGen

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Posted 06 February 2015 - 04:23 PM

My concern is with the post-cooking introduction of contamination (e.g. the starch bed!).

I am totally with you! You could re-introduce MOs by using starch.

 

Whats your target group? adults?

Do you have any historical data regarding micro sampling of your starch?

How much is the amount of starch in the end product? I don´t want to know your recipe ;) but is it less than ... lets say..1%?

 

Because you have to think about the influence a potentially contaminted starch would have --> less than 1%..... how much of the product do you have to eat until you get affected? Is it a reasonable daily amount?

 

So maybe a monitoring of your starch might be sufficent. And its a compromiss between you and the management .....but you should make a risk assessment with these questions in mind.



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fgjuadi

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Posted 06 February 2015 - 04:51 PM

What's the aw?


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AJ1795

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Posted 06 February 2015 - 04:55 PM

What's the aw?

 

aw = ~0.6.  ~15% moisture.



fgjuadi

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Posted 06 February 2015 - 05:38 PM

Maybe these will help you out - they reference outbreaks with lower aw


Edited by magenta_majors, 06 February 2015 - 05:41 PM.

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AJ1795

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Posted 06 February 2015 - 05:46 PM

Maybe these will help you out - they reference outbreaks with lower aw

 

 

I'm assuming you've had to use these in to counter the "no risk" argument as well  ;).  Although I wish none of us had to put up with management resistance, I have to admit I find it comforting knowing that I am not alone!  Thank you so much for your help!



Jeffrey Ort

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Posted 08 February 2015 - 10:21 PM

You could perform quarterly raw materials and finished goods testing. The cost is not as prohibitive and it is a verification of system that the product is safe. It will also create a parenthesis of time line for recall or withdrawal. Are you SQF or BRC certified, if so, what does your program require?






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