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2.5.2 Critical limit validation - kill step revalidation question


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#1 idealdreams

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Posted 14 July 2016 - 05:12 PM

SQF 2.5.2 states that critical limits must be scientifically validated and subsequently re-validated on an annual basis. We employ a kill step during our cooking process to eliminate potential salmonella, which was validated to a 6 log reduction from data collected in a lab trial last year.

 

We hired a third party laboratory/consulting group and this validation was not cheap (read several thousand dollars). I am wondering if SQF is saying it's necessary to scientifically validate this kill step every year? If so, that is unreasonable for us as we are a small company and cannot afford to appropriate funds in this manner. What other ways do I have to validate this? Our cooking process does not change so the validation is still valid.

 

 



#2 Tomato Country Girl

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Posted 14 July 2016 - 08:01 PM

I believe SQF is wanting you to make sure every year that the method you used to validate is still current. You can also validate your step by using scientific studies, university studies, that are applicable to your product/process that verify what you are doing is indeed scientifically sound.



#3 Charles.C

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Posted 14 July 2016 - 08:39 PM

I believe SQF is wanting you to make sure every year that the method you used to validate is still current. You can also validate your step by using scientific studies, university studies, that are applicable to your product/process that verify what you are doing is indeed scientifically sound.

 

Hi TCG,

 

Not a SQF user but it seems surprising that a cooking critical limit could be meaningfully revalidated without current  process validation data ?

 

(or do SQF allow initial validation solely by quoting a reference - SQF's handling of "validation" is famously individualistic)

 

On the other hand, from memory, critical limits in haccp plans are typically only required to be revalidated if something "significant" changes in the process or in relevant external knowledge. If so it is not obvious why SQF require an automatic annual revalidation. Unless the revalidation simply requires stating that the process is unchanged / no complaints etc, etc.

 

Unfortunately the SQF glossary has no info. on "revalidation".


Kind Regards,

 

Charles.C


#4 Tomato Country Girl

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Posted 14 July 2016 - 08:47 PM

Charles you are correct, we go through our scientific validation sources and check every year to make sure there have been no changes to the validation source.  Not surprising revalidation is not in glossary however if you check module 2 guidance under 2.5.2 Validation and Effectiveness.

 

Kind Regards,

 

Susan 



#5 Charles.C

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Posted 14 July 2016 - 09:05 PM

Charles you are correct, we go through our scientific validation sources and check every year to make sure there have been no changes to the validation source.  Not surprising revalidation is not in glossary however if you check module 2 guidance under 2.5.2 Validation and Effectiveness.

 

Kind Regards,

 

Susan 

 

Hi Susan,

 

Thks for the above. Indeed i had already scanned the piece of "Guidance" and noticed -

 

Critical food safety and quality limits are said to be validated because they have been confirmed by scientific analysis

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Sort of "classic" SQF. :smile:


Kind Regards,

 

Charles.C


#6 idealdreams

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Posted 15 July 2016 - 03:30 PM

Alright, thanks for the help everyone! I'm thinking I'll just make a document stating that the process has gone unchanged since the validation last year and if that's not sufficient for the auditor then I'll cross that bridge when I come to it and go from there.



#7 SmallMilk

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Posted 23 July 2016 - 03:52 AM

In my opinion you could conduct cooking equipment survey annual and make sure it is compliant with describable details in the validation report from your third party service. 

Good luck!






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