HACCP auditor said we need to check for Radiation & Aflatoxins?

Hello everyone:

We are a small business and  manufacture Ready to Eat Salad Dressing - both refrigerated and shelf stable...We went through our first HACCP audit in 2015 and received a 98%....but our auditor said we need to check for radiation and aflatoxins by our next audit....

From the research I have done I am not seeing where this is a major concern in the United States...We only sell and ship in the US....Where exactly should I address these two?  Hazard Analysis?  

Still learning and need some advice...

Thanks,

Sharon

Hi Sharon,

We identified this as well at our hazard analysis even though we are not exporting.

You can refer to the Codex standards which can be downloaded online.

Codex General Standard for Contaminants and toxins in Food and Feeds Codex Stan 193-1995

hope this helps.

cheers,

zene

Hello everyone:

 

We are a small business and  manufacture Ready to Eat Salad Dressing - both refrigerated and shelf stable...We went through our first HACCP audit in 2015 and received a 98%....but our auditor said we need to check for radiation and aflatoxins by our next audit....

 

From the research I have done I am not seeing where this is a major concern in the United States...We only sell and ship in the US....Where exactly should I address these two?  Hazard Analysis?  

 

Still learning and need some advice...

 

Thanks,

Sharon

Hi Sharon,

I anticipate it relates to FSMA.

Some US posters will probably be able to give more detail.

FSMA does indeed require your food safety plan to assess radiological hazards (which I never quite understood, unless you use radiation as part of your process).

However, aflatoxins, specifically, are not mentioned in the scope of FSMA. So I'm not sure which hat that rabbit was pulled out of.

Marshall

Thank you everyone...This gives me some reassurance as we will head back into our 3rd party audit February 2016...My head was starting to spin after reading everything I could on radiation and aflatoxins and wondering how these have any connection to ingredients in Salad Dressing..... :headhurts:

Sharon

Hi Sharon,

TBH, my earlier post related to radiology, I didn’t notice the aflatoxin. :smile:

Not sure if pre-included in the "dressing" but there are 3 previous threads here on haccp/salad cream/mayonaisse. Maybe of some usefulness -

http://www.ifsqn.com...dressing-haccp/

http://www.ifsqn.com...salad-dressing/

http://www.ifsqn.com...ogical-hazards/

None of the above seem to mention aflatoxin however googling does get some hits. The audit query was possibly with respect to an ingredient, eg

Consumption of edible oils derived from conventional crop plants is increasing because they are generally regarded as more healthy alternatives to animal based fats and oils. More recently there has been increased interest in the use of alternative specialty plant-derived oils, including those from tree nuts (almonds, pistachios and walnuts) and botanicals (borage, evening primrose and perilla) both for direct human consumption (e.g. as salad dressings) but also for preparation of cosmetics, soaps, and fragrance oils. This has raised the issue as to whether or not exposure to aflatoxins can result from such oils. Although most crops are subject to analysis and control, it has generally been assumed that plant oils do not retain aflatoxins due to their high polarity and lipophobicity of these compounds. There is virtually no scientific evidence to support this supposition and available information is conflicting. To improve the safety and consistency of botanicals and dietary supplements, research is needed to establish whether or not oils used directly, or in the formulation of products, contain aflatoxins.

 

http://www.ncbi.nlm....les/PMC2858461/

aflatoxin.png   80.94KB   0 downloads

Any peanuts in it ??

Hi Charles:

Thank you for the information....I am reading it all right now.... We use soybean oil (Refined, bleached & deodorized)... We don't use any nuts, corn, ginger, nutmeg etc.........and the research I have found in the "Bad Bug Book" (FDA)    Foodborne Pathogenic Microorganisms and Natural Toxins says:  "In the US, strict regulations in place since 1971, as well as FDA monitoring of the food supply and population's consumption of a diverse diet, have prevented human health problems, at the time of this writing, no outbreaks of aflatoxicosis have been reported in humans in the US"...  So,  for the hazard analysis...the risk would be considered low?  

I have not seen this in FSMA  (HARPC) - which is what we are all watching closely here in the US....and Marshall confirmed this, too....and an interesting side note....Our auditor's paperwork spelled it Aflo Toxin....

Sharon

:smile:

FSMA does indeed require your food safety plan to assess radiological hazards (which I never quite understood, unless you use radiation as part of your process).

However, aflatoxins, specifically, are not mentioned in the scope of FSMA. So I'm not sure which hat that rabbit was pulled out of.

 

Marshall

What is your opinion on its application to irradiated ingredients such as spices?  Specifically the facility that receives and uses spices that were irradiated at their supplier?

Hi Charles:

 

Thank you for the information....I am reading it all right now.... We use soybean oil (Refined, bleached & deodorized)... We don't use any nuts, corn, ginger, nutmeg etc.........and the research I have found in the "Bad Bug Book" (FDA)    Foodborne Pathogenic Microorganisms and Natural Toxins says:  "In the US, strict regulations in place since 1971, as well as FDA monitoring of the food supply and population's consumption of a diverse diet, have prevented human health problems, at the time of this writing, no outbreaks of aflatoxicosis have been reported in humans in the US"...  So,  for the hazard analysis...the risk would be considered low?  

 

I have not seen this in FSMA  (HARPC) - which is what we are all watching closely here in the US....and Marshall confirmed this, too....and an interesting side note....Our auditor's paperwork spelled it Aflo Toxin....

 

Sharon

:smile:

Hi Sharon,

So what else is in the salad dressing other than refined edible soyabean oil (which IMO is unlikely to be an aflatoxin risk due its nature/processing) ? fruit = ? vegetables = ? Herbs, Spices = ? etc. Organic ??

I had a quick look through Microorganisms in Foods/ICMSF which, for aflatoxins, yielded -

nuts – peanuts, several others (already noted absent)

fresh fruits – figs

spices – various

cereals – maize (= corn?? already noted absent)

Does the dressing have an ingredient  specification (normally mandatory for commerce/HACCP) ? (including a limit for aflatoxin ?)

(Might have been easier to ask the auditor why aflatoxin ?  :smile: ) (maybe he/she was just nitpicking)

PS - I guess aflotoxin sounds better than mycatoxin :smile:

What is your opinion on its application to irradiated ingredients such as spices?  Specifically the facility that receives and uses spices that were irradiated at their supplier?

I have none. Since we do not use these ingredients. Is there a level that is not to be breached for irradiation? Is it on the spec sheet? Is it on the COA?

Marshall