5 replies to this topic

[s.sirek]

Hello to all.  I have completed the PCQI training, and am now in the works of putting it all together.  I am confused, however, because our company is much different than most of the examples presented.  We re-pack or shrink wrap products sent to us directly from our customers, who do the manufacturing.  All packaging cartons for the food are also sent directly from our customers.  All food products are sealed - no exposed food is handled here. Some are RTE w/allergens, some are RTE w/o allergens, some are NRTE w/ allergens, and some are not food at all.  My question is this........ do I have to create separate food safety plans for each category listed above, or can I consolidate - and document the allergen and supply chain controls needed for each product?  Your advice would be much appreciated.  I'm new in the industry, and learning every single day!  Thanks so much!

 

[Ryan M.]

Hi S.sirek and welcome!

 

On the RTE items, do any of them require chilling/freezing as a method of food safety?  For example, are they low pH, high pH, low moisture, high moisture foods?  This matters because RTE is considered a higher risk, especially if the pH and moisture are in the right ranges.  This is even if you don't expose the food because improper temperature conditions can lead to pathogen outgrowth even if the RTE food has undergone treatment for pathogens of some type (heat, high pressure, etc).

 

I would look at this first and see which items require chilling/freezing for food safety.  If this is required then you need to address it in your food safety plan with a supplier control and what would be an "other control" which would be storage conditions.  From suppliers you would want to get statements concerning the safety of the materials within certain storage conditions.  For example, a perishable item that is RTE would be required to have refrigeration or freezing as a safety control since it is perishable (high pH, and/or high moisture).

 

As far as the allergens, this is more straight-forward since everything is sealed.  I would identify an allergen control plan stating you handle foods with the following allergens listed and all foods are sealed.  Then you would have some SOP when any of the food containing an allergen is isolated, segregated, and appropriate clean up or other action is taken to prevent cross contact with non-allergen or different allergen materials.

 

I hope this helps to clarify.

 

Ryan

[Matthewlee]

Hello S.sirek

 

Could you please tell me what RTE is?

 

Matthew

[classic]

RTE = Ready to eat

 

Regards

 

Classic

[s.sirek]

Hi S.sirek and welcome!

 

On the RTE items, do any of them require chilling/freezing as a method of food safety?  For example, are they low pH, high pH, low moisture, high moisture foods?  This matters because RTE is considered a higher risk, especially if the pH and moisture are in the right ranges.  This is even if you don't expose the food because improper temperature conditions can lead to pathogen outgrowth even if the RTE food has undergone treatment for pathogens of some type (heat, high pressure, etc).

 

I would look at this first and see which items require chilling/freezing for food safety.  If this is required then you need to address it in your food safety plan with a supplier control and what would be an "other control" which would be storage conditions.  From suppliers you would want to get statements concerning the safety of the materials within certain storage conditions.  For example, a perishable item that is RTE would be required to have refrigeration or freezing as a safety control since it is perishable (high pH, and/or high moisture).

 

As far as the allergens, this is more straight-forward since everything is sealed.  I would identify an allergen control plan stating you handle foods with the following allergens listed and all foods are sealed.  Then you would have some SOP when any of the food containing an allergen is isolated, segregated, and appropriate clean up or other action is taken to prevent cross contact with non-allergen or different allergen materials.

 

I hope this helps to clarify.

 

Ryan

Thanks for your help, Ryan.  I should have clarified.  ALL products we handle require NO refrigeration/freezing.  Pretty straight forward re-packing of sealed bowls of cereal, oatmeal pouches, cookie mixes, and hot chocolate drink mixes, along with many non-food products.  Some RTE, some NRTE.  May also be important for you to know that some are just taken out of a case, and put in another case as a variety pack, and others get shrink wrapped and re-cased.  We are SQF certified, and had only one HACCP plan.  Just not sure if I should separate these by RTE/NRTE, Allergen/non-Allergen, by process, or keep them together with the new Food Safety Plan. 

[Ryan M.]

Nice...that makes it much easier.  I would just separate by RTE/NRTE and Allergen/non-Allergen.

 

One thing to note with FSMA Preventive Controls you will need to provide some statement to your customer that the NRTE items have not undergone a process control and will need treatment to ensure they do not pose a health risk.  Here is a statement we receive from one of our suppliers of cream:

 

"Per the new Preventive Controls Requirements (21 CFR 117.136)

 

NOTE: The heat treated cream being supplied has NOT been sufficiently processed to completely control the pathogens associated with raw milk.  Your firm/company is responsible for taking those measures to control pathogens associated with raw milk."

 

This also depends on if the NTRE items are by their very nature are typically consumed after further processing, or are there instances where the NTRE items can be consumed or used as an ingredient without further processing?  If the latter is the case, then you need to provide some type of statement like the one above.  If the former is the case then you need a statement for your records indicating the NTRE are not consumed without further processing.  However, I would caution against the former because you never really know.