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Contamination of Raw Fish from Floor

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Best Answer , 20 January 2016 - 07:21 PM

Hi Raymond,

 

I think most of yr queries were answered in my previous post.

 

The related thread for meat I referred to is here -

 

http://www.ifsqn.com...d-on-the-floor/

 

Particularly note post 15


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RaymondD

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Posted 20 January 2016 - 04:58 AM

Good day!

 

We had recently have our first external audit for canned tuna products and one of the minor findings was:

 

"Based on hazard analysis and assessment of associated risks, there shall be a program to control effectiveness of hand hygiene.

One butcher was observed collecting a raw fish that fall and come in contact with the floor and returned it back to the work table without cleaning the fish and washing his hands. There is no clear procedure to handle raw fish material that fall and come in contact with the floor."

 

Kindly note: the butcher removes the intestines and entrails of the fish before it is sent to precooking (initial heat treatment).

Would like to ask if it is a valid corrective action to thoroughly rinse the fish and return it back to the work table? is there need to identify the fish that come in contact with the floor after it has been rinsed thoroughly? or outright rejection of the fish which is not economical?

 

May I solicit advises to formulate a valid corrective action to close the non-conformity. Had searched around the internet and there were no straight answers to how to properly handle the case.

 

Hoping your soonest replies.

 

Thank you and God bless!



Charles.C

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Posted 20 January 2016 - 06:33 AM

Hi Raymond,

 

i deduce the dropped product was whole fish.

 

The answer could depend on the condition of the floor. And the water supply, chemicals etc, etc (ie a risk assessment of the potential contamination/process). Final product is skin-on (I anticipate not) ?

 

If you consider any BCP risk may be eliminated by washing, would seem a basically reasonable procedure. If you wished, could always isolate one particular event / product and run some tests to validate yr judgement.

 

IMEX of raw whole fish processing (non-tuna), a procedure of washing/dipping in (weak) hypochlorite solution was used. And similarly with respect to the worker's hands (gloves). Offhand, I also do not recall seeing a specific procedure in print. Probably the auditor doesn't also but they tend to like to see some documentation.

 

BTW, I recall a previous thread here noted that washing of dropped "meat" in early process stages is a recognized acceptable activity in USA/USDA. JFI. :smile:


Kind Regards,

 

Charles.C


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RaymondD

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Posted 20 January 2016 - 08:28 AM

Good day Sir Charles,

 

Thank you Sir.

 

Yes sir, the dropped product is a whole fish and the final product is canned tuna.

 

The floor of the processing plant is made from Polyurethane with antibacterial properties and the water supply is chlorinated.

 

Maybe In our case, the associated risks that maybe of great concern when the raw fish comes in contact with the floor would maybe the foreign matter that may cling to the raw whole fish but washing the fish thoroughly would greatly reduce the risks, hence washing the fish after when it comes in contact with the floor would be an acceptable counter measure, is it right sir?

 

But a validation would be necessary to verify that the BCP risk is minimal, right sir?

 

Sir may I also ask for the link of the thread or published material that highlights the acceptability of the counter measure for the case, would be using it as a reference to support the procedure will be making to handle the same case. We are planning to include it in our GMP-SSOP Manual.

 

Thank you very much Sir Charles.

 

God bless you :)



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Posted 20 January 2016 - 07:21 PM   Best Answer

Hi Raymond,

 

I think most of yr queries were answered in my previous post.

 

The related thread for meat I referred to is here -

 

http://www.ifsqn.com...d-on-the-floor/

 

Particularly note post 15


Kind Regards,

 

Charles.C


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RaymondD

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Posted 22 January 2016 - 04:16 AM

Good day Sir Charles

 

Yes Sir most of it were answered, I'am just uncertain of my conclusion I have drawn-out.

 

Thank you for the link Sir.

 

Thank you and God bless you :)





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