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Is addition of food grade CO2 or Nitrogen classed as compressed air


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#1 Carol88

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Posted 15 February 2015 - 07:43 PM

Hi everyone, can anyone tell me if food grade CO2 or nitrogen being sparged directly into vegetable mash prior to concentration to stop browning of product is classed as adding compressed air and therefore should be tested regularly for bacteria contamination. We are under SQF which have a section on compressed air. If it is classed as adding compressed air then how would you check for bacteria contamination  and how often. Any help would be appreciated. Thank you. 



#2 shea quay

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Posted 15 February 2015 - 11:58 PM

No, it is not. You are purchasing your food grade gas from an approved supplier (I hope!), therefore it is a treated as a raw material. Your risk assessment may raise a low risk concerning microbiological risk from bugs in the pipework (low risk), chemical risk (covered by your supplier's accreditation) and intrinsic risk (dosing pumps misfiring resulting in incorrect gas mixtures, maintenance risk of some maintenance person messing up pipework), but everything else is down to the supplier. I used to work in the frozen vegetable industry. The largest issue I had was people breaking a musical chorus of "Let's face the music and blanch!". Health and Safety nightmare. Guys coming into work in tap shoes, incredible umbrella based dance routines, uncompleted paperwork. It's a tough industry. 

If you have used your HACCP plan to identify this step of the process as a CCP (from your description, I would guess not - CP at most), then I would say that, though there may be trouble ahead, while there's moonlight and music and love and romance, review your supplier approval process and blanch. 



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#3 Snookie

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Posted 16 February 2015 - 04:57 PM

At another plant we had nitrogen which was used for flushing.  We were also SQF.  Our auditor treated it as compressed air.  We had to demonstrate that it was food grade, properly filtered and tested.  For test purposes we treated it like we treated the compressed air


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#4 Charles.C

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Posted 16 February 2015 - 08:11 PM

Dear Carol,

 

FWIW, the BCAS (2006) Compressed Air Standard has these comments -

 

This Code of Practice does not cover the use of compressed air as a food ingredient.

NOTE: - This code does not cover other gases commonly used in the food industry (such as nitrogen and carbon dioxide), which should be controlled, as they will have an impact on the quality of the final food or beverage.

 

I presume the finished vegetable mash is RTE.

 

One, "best" case interpretation of SQF's  micro requirements for compressed air (CA) is here -

 

Attached File  Compressed-Air-for-Food-GMPs.pdf   556.32KB   77 downloads

 

I daresay the attachment 's POV would suggest an equivalent approach for N2, CO2 in present case, ie filtered, verifiable, sterility.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#5 Carol88

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Posted 16 February 2015 - 10:38 PM

Dear Carol,

 

FWIW, the BCAS (2006) Compressed Air Standard has these comments -

 

I presume the finished vegetable mash is RTE.

 

One, "best" case interpretation of SQF's  micro requirements for compressed air (CA) is here -

 

attachicon.gifCompressed-Air-for-Food-GMPs.pdf

 

I daresay the attachment 's POV would suggest an equivalent approach for N2, CO2 in present case, ie filtered, verifiable, sterility.

 

Rgds / Charles.C

Hi Charles the product is not RTE after being sparged it then goes through a decanter, pasturized and concentrated. I have contacted an auditor who in his opinion says that he would class it as a raw material (not compressed air) which comes from an approved supplier who can verify that it is food grade. he would also ensure that the hose connection is sanitized and swabbed or TPC conducted. In summery so long as I can prove that it is being controlled I should be fine. I want to thank you for your imput and I am thinking of going down the track of controlling it as a raw material unless after I am audited the auditor says that it needs to be treated as compressed air



#6 Charles.C

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Posted 17 February 2015 - 01:38 AM

Dear Carol,

Thanks for the info.

There are 2 aspects IMO, (1) the risk assessment, (2) SQF's own "risk" viewpoint.

(1)
The product status, eg RTE or not, has a considerable influence on the whole hazard analysis as I'm sure you know. The status of RTE or not depends on the consumer handling / Labelling. No idea as to the intended use of yr product.
Normally the intention of pasteurization is to achieve a RTE finished product. Would seem you have an unusual process.
Personally not a SQF user and I agreed with shea quay's proposed hazard analysis procedure. But the risk assessment will always depend on the detailed product/process/consumer usage,etc. HA 101.

(2)
If you look back through the SQF forum threads concerning compressed air and certain other topics, you will see that SQF can be a notoriously fickle organization when it comes to their interpretation of other standards and consistency within their own standard. Just as an example, the CA guidance on their website essentially  contradicts that in their Manual. Reason unknown. Likely auditorial choice seemingly random. Snookie's post is a possible example of one (anomalous?) response but not in any way a general validation.

I'm not a SQF user so my comments are based solely on numerous SQF audit events as posted here. But how much representative of the norm is unknown. A job for your Practitioner perhaps ?

 

Good Luck !

Rgds / Charles.C


Kind Regards,

 

Charles.C


#7 Snookie

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Posted 17 February 2015 - 05:10 PM

 Snookie's post is a possible example of one (anomalous?) response but not in any way a general validation.

 

In this case most likely not anomalous.  It all depends on the process and risk levels.  In case I mention it was used as a flush for finished RTE.   In the initial post was not sure of the process or the risk factors which is why I mentioned it.  By treating it as we did it also served as confirmation as to the integrity of the lines.


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#8 Charles.C

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Posted 17 February 2015 - 07:37 PM

In this case most likely not anomalous.  It all depends on the process and risk levels.  In case I mention it was used as a flush for finished RTE.   In the initial post was not sure of the process or the risk factors which is why I mentioned it.  By treating it as we did it also served as confirmation as to the integrity of the lines.

 

Dear Snookie,

 

After some reflection, it appears that, for compressed air,  these SQF criteria apply to both raw/RTE foods -

 

compressed air (CA) used in the manufacturing process shall be clean and present no risk to food safety.”   
compressed air used in the manufacturing process shall be regularly monitored for purity.”

 

The Guidance Manual's response to above with respect to micro. control  (in  11.5.7.1) is  -

 

Wherever the compressed air comes in contact with the food, either directly or indirectly, high efficiency filters are to be in place at point-of-use where the air enters the final section of tubing (not in the compressor room).

 

And -
 

 

The recommended final stage of filtration in these food contact areas should have a rating of 0.01 micron with an efficiency of 99.999% (or as determined by appropriate risk analysis).  Sufficient filtration is to be in place directly upstream of the final stage to protect the final stage from oil and water aerosols.
Nozzles and air hoses are to be in good condition, properly repaired and maintained in a hygienic state (e.g.,cleaned and sanitized). Hoses and nozzles are to be kept off the ground.  
It is generally advisable to locate the filtration as close as practically possible (near the “point of use,” or the point where air contacts the food), so as to not have long lengths of piping/tubing between the microbial removal filter and the air/food contact point.

 

The underlined portion is elsewhere interpreted in various ways as discussed in older threads here. Proposals for other, more tolerant, filtering methods exist (eg the SQF website). from an audit POV, the recommended expectations from SQF to their auditors seem to be unknown. In practice, it is so far equally unclear as to the actual rules in place.

 

The above is for compressed air which will consequently be essentially sterile at POU.. Whether the presentation in the Guidance Manual is actually followed by SQF (or how much followed)  is, quite simply, unknown.

 

The question from OP's  POV is whether N2, CO2 will also be treated as above. This, afai can see is unspecified in the Code/Guidance Manual  although it can be claimed that the Guidance proposed system for CA  is microbiologically  "as good as it gets", ie "Best Practice".

 

From a risk analysis POV, it presumably becomes a question of the risk difference between delivery systems (eg gas/cylinder/lines vs air/compressor/lines) for aspects like oil contaminants but from a micro. POV i daresay the CA-SQF Guidance still represents "best practice", ie a sterile input.

 

Clearly there is a substantial cost/effort difference between implementing the CA logic as compared to using an approved supplier.

 

@ Carol - It would be nice to be informed of the audit results regarding above.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#9 Snookie

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Posted 17 February 2015 - 07:57 PM

Great research Charles.  I too look forward to audit results. 


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#10 Carol88

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Posted 17 February 2015 - 08:18 PM

Dear Snookie,

 

After some reflection, it appears that, for compressed air,  these SQF criteria apply to both raw/RTE foods -

 

compressed air (CA) used in the manufacturing process shall be clean and present no risk to food safety.”   
compressed air used in the manufacturing process shall be regularly monitored for purity.”

 

The Guidance Manual's response to above with respect to micro. control  (in  11.5.7.1) is  -

 

 

And -
 

 

The underlined portion is elsewhere interpreted in various ways as discussed in older threads here. Proposals for other, more tolerant, filtering methods exist (eg the SQF website). from an audit POV, the recommended expectations from SQF to their auditors seem to be unknown. In practice, it is so far equally unclear as to the actual rules in place.

 

The above is for compressed air which will consequently be essentially sterile at POU.. Whether the presentation in the Guidance Manual is actually followed by SQF (or how much followed)  is, quite simply, unknown.

 

The question from OP's  POV is whether N2, CO2 will also be treated as above. This, afai can see is unspecified in the Code/Guidance Manual  although it can be claimed that the Guidance proposed system for CA  is microbiologically  "as good as it gets", ie "Best Practice".

 

From a risk analysis POV, it presumably becomes a question of the risk difference between delivery systems (eg gas/cylinder/lines vs air/compressor/lines) for aspects like oil contaminants but from a micro. POV i daresay the CA-SQF Guidance still represents "best practice", ie a sterile input.

 

Clearly there is a substantial cost/effort difference between implementing the CA logic as compared to using an approved supplier.

 

@ Carol - It would be nice to be informed of the audit results regarding above.

 

Rgds / Charles.C

Hi Charles, our audit is not until August and yes it will be interesting as I have noticed all auditors seem to have a different view  on certain aspecs of the SQF manual.






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