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Floor Sweep & BRC

nuts floor sweep microbiological

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#1 HochderfferT

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Posted 13 May 2015 - 04:37 PM

I work in a nut processing plant (dry environment) and we recently ran into a problem where we had certain individuals wanting to run our "floor sweep" for human consumption rather than trash it, I was hoping someone might know if BRC/FDA would potentially back this should it be done in a way to minimize potential contaminants, our ideas so far on it were to sweep up any nut meats (no trash or foreign materials) into a bin and store any bins for a designated period (1 month, 1 year) and have a switch over procedure similar to our organic switch overs involving cleaning and sanitizing all equipment prior to and after running any of the floor sweeps, and then have it immediately pasteurized, and then tested for micros and put on hold until the CofA's come back from the lab. what are your guys thoughts on this be it another way around the issue or if this would even be allowable with BRC (we are hoping to gain BRC certification) or FDA, any help on this is greatly appreciated! if it's not allowed per either a source for this or at least a location to look myself would be greatly appreciated to show to the individuals, cheers! :helpplease:



#2 Sagar_J

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Posted 13 May 2015 - 05:31 PM

Hi Hochderffer, 

 

Although on the first glimpse the answer to your question would be negative since it involves floor sweep, one can present a significant argument to go with the idea based on following factors like location of the floor sweep (internal / external), PRP's at the location, Methods to control / prevent cross contamination from the floor sweep, Roasting / Blanching / Colour Sorting / Mechanical methods to be used, what analysis to be done for a positive release, change over procedures etc..

 

IMO BRC does not mention about it directly but there may be several indirect representation and in a sense everything that is related to cross contamination can be implicated here. IMEX it may also come down to figures ultimately as to how much of your raw material are you saving. Compared to your output if this number is a small proportion it is best to discard. Also if the floor sweep also involves external or peripheral areas along with internal area there is automatically a greater possibility of cross contamination.

 

IMO apart from obvious cross contamination issue that you will have to face another thing I would worry about is loss of traceability. Assuming your floor sweep contain more than one lot of raw input how would you back trace it to the supplier? 

 

Hope this helps. Its an interesting question. 

 

Thanks, 



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#3 HochderfferT

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Posted 13 May 2015 - 06:07 PM

Hi Hochderffer, 

 

Although on the first glimpse the answer to your question would be negative since it involves floor sweep, one can present a significant argument to go with the idea based on following factors like location of the floor sweep (internal / external), PRP's at the location, Methods to control / prevent cross contamination from the floor sweep, Roasting / Blanching / Colour Sorting / Mechanical methods to be used, what analysis to be done for a positive release, change over procedures etc..

 

IMO BRC does not mention about it directly but there may be several indirect representation and in a sense everything that is related to cross contamination can be implicated here. IMEX it may also come down to figures ultimately as to how much of your raw material are you saving. Compared to your output if this number is a small proportion it is best to discard. Also if the floor sweep also involves external or peripheral areas along with internal area there is automatically a greater possibility of cross contamination.

 

IMO apart from obvious cross contamination issue that you will have to face another thing I would worry about is loss of traceability. Assuming your floor sweep contain more than one lot of raw input how would you back trace it to the supplier? 

 

Hope this helps. Its an interesting question. 

 

Thanks, 

Thank you very much, this was some of what we had thought about too it's nice to have someone agree with our thoughts, I greatly appreciate the input I'll look into the cross contamination requirements etc. per BRC and see if I can locate anything there that will be of help to us, definitely still eager to hopefully hear from other sides as well if anyone has or has tried to implement a system, I'm personally leaning more towards trashing it as well (which is per usual) but I at least need to look into it for said individuals, thanks again for the input it helps tremendously! :thumbup:







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