55 replies to this topic

[sarah2014]

we had an USDA  inspection and the inspector didn't like this practice of our shrimp salvage even though our records shows that we never had a customer complaint or a recall . we are testing our  finished product monthly and we do environmental testing quarterly  all the results are good. plus we use an FDA approved sanitizer for the floor .

 

 

this is what our SOP says :

Shrimp that fall directly on the floor (Production lines)

• Using the approved Floor Use Only - RED Tools (Shovel, Squeegee), remove the shrimp from the floor and place them in a RED ‘Salvage’ Tub that is designated for this purpose.
• This action should be taken at least once every 15 minutes.
• All ‘Salvaged’ shrimp are to be thoroughly washed at the ‘Salvage’ Sink that has been designated for this purpose.
• These shrimp are to be inspected, at the ‘Salvage Station’ for damage or quality defects.
• Good quality shrimp are to be placed back into the production Stream as needed.
• Poor quality shrimp (damaged and or pieces) are to be placed into the appropriate product type, or find the appropriate disposition (i.e.: destruction).

 

if any one has experience in a  seafood plants please advise

 

Thank you

[Charles.C]

Hi Sarah,

 

I have experience in a seafood processing Plant.

 

Is this incoming raw shrimp ? shell-on ? processed raw shrimp meat ? RTE shrimp meat ?

 

The risks will vary of course.

 

Which element(s) did the inspector not like ? What did he/she want you to do ?

[Charles.C]

addendum

 

Offhand, assuming the floor is not a risk for chemical contamination/any other floor hazards not removable by washing-later processing, i thought yr procedure looked OK for small numbers of dropped, raw, shell-on shrimp to be eventually peeled. I have worked with far less elaborate SOPs which received no auditorial criticism (not in USA though).

 

IMO would be inappropriate for cooked shrimp though.

[sarah2014]

_{Raw IQF SHRIMP shell-on and peeled and deveined.}

 

 

 

_{the inspector didn't like the fact that we  take the shrimp that fall directly on the floor Using the approved Squeegee and place them in a RED ‘Salvage’ Tub that is designated for this purpose.}

 

 

_{All ‘Salvaged’ shrimp are to be thoroughly washed at the ‘Salvage’ Sink that has been designated for this purpose.These shrimp are to be inspected, at the ‘Salvage Station’ for damage or quality defects.Good quality shrimp are to be placed back into the production Stream as needed.Poor quality shrimp (damaged and or pieces) are to be placed into the appropriate product type, or find the appropriate disposition.}

 

_{we use an approved sanitizer for the floor our records were good every month we test for e coli and  staphylococcus also we test for listeria quarterly .}

_{please if you have any experience with IQF SHRIMP let me know what do you guys do with the shrimp that falls on the floor}

_{Thank you}

[Charles.C]

_{Raw IQF SHRIMP shell-on and peeled and deveined.}

 

_{the inspector didn't like the fact that we  take the shrimp that fall directly on the floor Using the approved Squeegee and place them in a RED ‘Salvage’ Tub that is designated for this purpose.}

 

_{All ‘Salvaged’ shrimp are to be thoroughly washed at the ‘Salvage’ Sink that has been designated for this purpose.These shrimp are to be inspected, at the ‘Salvage Station’ for damage or quality defects.Good quality shrimp are to be placed back into the production Stream as needed.Poor quality shrimp (damaged and or pieces) are to be placed into the appropriate product type, or find the appropriate disposition.}

 

_{we use an approved sanitizer for the floor our records were good every month we test for e coli and  staphylococcus also we test for listeria quarterly .}

_{please if you have any experience with IQF SHRIMP let me know what do you guys do with the shrimp that falls on the floor}

_{Thank you}

 

Hi Sarah,

 

I'm unclear why the inspector didn't like the red text above ? i assume you mean he accepted the dropped shrimp  to be further utilised but not, somehow, "handled/treated" as per yr SOP ?. (Presumably, if the inspector/USFDA(?) require a specific procedure/action you have no other options).

 

I cannot remember ever seeing this issue discussed in seafood texts/this forum but do note that it has come up in a previous thread here with respect to USDA-monitored meat processing. The USDA-acceptable "procedure" is IIRC noted in that thread.

 

Here is my "take" + some of my experience -

 

It is IMO unrealistic to assume that the micro. condition of the floor will match the equipment, etc used for routine handling of the shrimp.

 

Accordingly,  to minimize the risk of any eventual consumer safety-related incident due to retention of dropped shrimp, I suggest a few Prerequisites –

 

(1) Raw shrimp involved  must be "scheduled" to be cooked as against consumed raw. This to  assure  that any microbiological contamination will be eliminated. (But not chemical).

(2) The processing floor area involved is dedicated to shrimp.

(3) No “food incompatible” chemicals have been applied/remain on the floor surface under discussion.

(4) Floor physical condition / drainage systems / potential sources of cross-contamination are visually/historically satisfactory.

(5) Factory/process water supply is maintained to an available chlorine range of 1-4 ppm

 

Assuming the above, my suggested SOP is –

 

(a) Pick up any dropped shrimp (assumed visually clean/normal) with  sanitized (eg as per[c] below), disposable (for auditorial benefit), gloves

(b) rinse “briefly” in running water (as [5] above)

(c) dip “briefly” in a dedicated bowl of water maintained at approx 50-100 ppm available chlorine

(d) return shrimp to the processing table/equipment

 

The actual micro. result for the dropped product could be (test) monitored on a segregated sample if so desired. Offers a partial validation of methodology.

The relative risk to the end product logically increases as one progresses down the chain and particularly with peeled material cf. yet to be peeled.

Clearly No.(3) above is critical.

 

PS - On re-reading yr posts, I get the impression that a LOT of dropped shrimp may be involved. This might alter my above suggestions.

 

PPS - I am dubious as to the benefit of micro. monitoring the floor but it's only my opinion.

[sarah2014]

Thank you Charles.

 

no not a lot of shrimp, the inspector said that we need to provide proof that the current re-conditioning process fully eliminates any chemical or pathogenic materials from the re-conditioned shrimp.

 

we use floor guard sanitizer (Gras status) .

we process only shrimp

we test for e coli , staphylococcus monthly

we test for listeria quarterly  

we never had a food safety complaint

we never had a recall

all our certificate of analysis are good

[Charles.C]

Thank you Charles.

 

no not a lot of shrimp, the inspector said that we need to provide proof that the current re-conditioning process fully eliminates any chemical or pathogenic materials from the re-conditioned shrimp.

 

we use floor guard sanitizer (Gras status) .

we process only shrimp

we test for e coli , staphylococcus monthly

we test for listeria quarterly  

we never had a food safety complaint

we never had a recall

all our certificate of analysis are good

 

Hi Sarah,

 

Thks for above. I'm glad not a lot of dropped shrimp.

 

The inspector's comment is equivalent IMO to yr demonstrating on end product that the micro./chemical etc characteristics of re-conditioned shrimp (nice name !) are "equal" to the non-dropped. Or perhaps that both are satisfactorily compliant to yr product specification (micro counts are often considerably variable albeit still satisfying the specification).

Presumably, for raw shrimp, the typical key safety parameter is Salmonella non detected plus L.mono/E.coli/S.aureus all "low" and APC/coliform not "excessive".

I wouldn't know how you do any chemical validation though. I deduce from Google that Floor guard is a Quaternary compound. As i read its Tech.data sheet, the active ingredient is not claimed to be GRAS, ie -

 

The  active  ingredients  are  a  dual  chain  quaternary  ammonia.  
The  balance  of  FLOOR  GUARD  ingredients  are  inert  and
classified  Generally  Recognized  As  Safe  (GRAS  status),  in
accordance  with  21  CFR  part  184.  Registered by NSF, Reg.
No. 122923-(P1). This product is 100% biodegradable.

 

[sarah2014]

but on the SDS SHEET that I have said is Gras

you think that we need to do chemical testing ?

[Charles.C]

but on the SDS SHEET that I have said is Gras

you think that we need to do chemical testing ?

 

Hi Sarah,

 

I attach SDS sheet from IT. can't see any GRAS, or any compositional details at all (!). Strange. Maybe there are multiple "Floor Guards" ?

 

 FLOOR-GUARD, SDS.pdf   57.11KB   22 downloads

 

You might investigate whether there is a Regulatory ppm limit to the amount of the active Quaternary component in seafood. I've never used Quats so no idea. I'm aware they are very popular in USA, and IIRC USDA also.

 

I guess the extent of any validation depends on what the inspector needs. They should have given you some idea IMO.

[Scampi]

We process RTC poultry----there is only one position where carcasses can be picked up and placed back in production and they cannot be HELD for any length of time and only before evisceration

 

I would double check your chem......the quat probably should have a potable rinse for food contact surfaces (assuming you're not already doing so), we only use quats for boot dips (the efficacy doesn't diminish due to bacteria load like sodium hypochlorite) and use a PPA for the santizing step

[Scampi]

When i look quickly at the FDA site, it says GRAS is for food additives only?  If that is correct (and i'm not saying it is) you may have been sailed upriver in your shrimp boat.

 

There isn't a "safe" level of quats generally speaking without a potable rinse, the technical sheet doesn't make me warm n fuzzy. I wouldn't rinse and put back into production with that product on the floor

[sarah2014]

before we return the shrimp to the line , the shrimp is washed and deglazed

[Scampi]

Perhaps your inspector is concerned with the holding temperature? or the shrimp being piled----can the SOP be altered so it's "as necessary" i.e. when shrimp hit the floor with zero lag time

[sarah2014]

we put the shrimp in a basket wit ice before we wash it . in each line there is a person responsible to collect the shrimp from the floor put it a dedicated basket with ice to maintain the temperature

[Scampi]

Ok, that sounds good.

So you're left with 2 options 

 

A) inspector was looking for a bone to pick

 

B) you may be picking up things other than shrimp with the shovel and placing them in a tote that I am assuming does not get cleaned during production thus increasing the bacteria load on the tote

[sarah2014]

no we have a second shift for sanitation they clean everything . before we start the production we do our pre-op to make sure everything is cleaned . also we use an ATP test

[Charles.C]

Hi Sarah,

 

JFI, the meat thread i referred to earlier is here -

 

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

(As you can see, this is a contentious topic. A USDA procedure is quoted/described in Post 15)

 

Another Procedure for "re-conditioning" meat(poultry/eggs)  -

 

The first requirement for a salvage (reconditioning) operation is a “meat sink”.
 
The “meat sink” is to be used only for meat reconditioning when identified as such.  
 
The second requirement is that the meat sink must have a false bottom with a minimum height of
2 inches from the bottom of the sink with perforations (holes) to allow the meat to be rinsed with
clean water not soaked or bathed.  
 
This sink may be used for other functions but not as a meat sink at the same time.
 
Each  time  it  is  to  be  used  as  a  “meat  sink”  it  must  be  cleaned/sanitized  and  inspected  by  the
Processing Inspector (P.I) prior to use as a meat sink.
 
The  third  requirement  is  that  the  “meat  sink”  be  identified  with  a  highly  visible  sign,  placed
above the sink when being used as a meat reconditioning sink.
 
Use of hand washing basins for cleaning product is not permitted.

   California, processing inspector training manual,2013.pdf   2.69MB   22 downloads

(Pg 66)

 

I also noticed  this FSIS "Procedure" -

If product incidentally drops on the floor in the raw product area, the utility person will promptly remove the product from the floor, trim the contaminated surfaces, wash the product at the product wash station, and re-inspect it for any contamination before placing it back into production. QA personnel will monitor the product reconditioning procedure twice a day.  If the establishment is not monitoring the product reconditioning procedure during the day, there is noncompliance with §416.13©

 

 FSIS Sanitation SOPs (2016).pdf   446.28KB   36 downloads

 

But i failed to find any comparable offerings in the Seafood Literature

[CMHeywood]

If the floor sanitizer is questionable for food contact, do you clean the red squeegee and the red bin after each use?  Do you clean the wash tank after each use?

 

If the shrimp on the floor are contaminated, then everything they touch is going to be contaminated when they are moved and re-conditioned?

[Fishlady]

My experience is that raw seafood (although it would not be recommended for peeled, raw shrimp) that falls onto the floor may be washed in fresh water and returned to the line.  You can also use a solution of acidified sodium chlorite (ASC) at up to 50 ppm for reconditioning the shrimp.  I would not recommend using chlorine in the rinse water- that used to be a common practice, but FDA now considers that unacceptable.  ASC has approval from FDA for this purpose.

[Charles.C]

My experience is that raw seafood (although it would not be recommended for peeled, raw shrimp) that falls onto the floor may be washed in fresh water and returned to the line.  You can also use a solution of acidified sodium chlorite (ASC) at up to 50 ppm for reconditioning the shrimp.  I would not recommend using chlorine in the rinse water- that used to be a common practice, but FDA now considers that unacceptable.  ASC has approval from FDA for this purpose.

 

Hi Fishlady,

 

i guess you are referring to this -
 

21CFR173.325

The additive is used as an antimicrobial agent in water and ice that are used to rinse, wash, thaw, transport, or store seafood in accordance with current industry standards of good manufacturing practice. The additive is produced by mixing an aqueous solution of sodium chlorite with any GRAS acid to achieve a pH in the range of 2.5 to 2.9 and diluting this solution with water to achieve an actual use concentration of 40 to 50 parts per million (ppm) sodium chlorite. Any seafood that is intended to be consumed raw shall be subjected to a potable water rinse prior to consumption.

 

I assume the above procedure is based on chlorine dioxide. I appreciate the potential benefits but I recall rejecting this many years ago for process water chlorination due the highly reactive nature of Na chlorite / storage-handling headaches. And the cost.

 

I could not find any directive regarding FDA's current non-acceptability of sodium hypochlorite. Can you supply a link ?

[Fishlady]

Hi Fishlady,

 

i guess you are referring to this -
 

 

I assume the above procedure is based on chlorine dioxide. I appreciate the potential benefits but I recall rejecting this many years ago for process water chlorination due the highly reactive nature of Na chlorite / storage-handling headaches. And the cost.

 

I could not find any directive regarding FDA's current non-acceptability of sodium hypochlorite. Can you supply a link ?

Yes your reference for ASC/chlorine dioxide is correct.  I have used it on fish but have not processed shrimp since this product was approved so don't know how it would react with shrimp.

 

Regarding chlorine, I would have to dig a bit to find the specific reference, but I remember a discussion with an FDA inspector on this topic.  The upshot was that a dip used for this purpose should not exceed 10 ppm chlorine.

[Charles.C]

Yes your reference for ASC/chlorine dioxide is correct.  I have used it on fish but have not processed shrimp since this product was approved so don't know how it would react with shrimp.

 

Regarding chlorine, I would have to dig a bit to find the specific reference, but I remember a discussion with an FDA inspector on this topic.  The upshot was that a dip used for this purpose should not exceed 10 ppm chlorine.

 

Hi Fishlady,

 

Thks. The 10ppm limit is certainly a transition from the once-recommended routine of 1000ppm ! Frankly, a10ppm/straight dip is probably only microbiostatic.

 

I deduce hypochlorite is still in use but has fallen out of favour compared to dioxide (in spite of cost perhaps), For fish anyway.

[Charles.C]

Hi Sarah,

 

Hopefully, you're still following this thread. I have one more comment / query.

 

After studying the  Floor Guard tech. sheet seems that 2 modes of use are possible - (a) for floors, simply apply the product to the floor and leave it there, ie  no follow-up rinse or (b) add a rinse step directly afterwards as advised in the (end) tech.sheet caveat - 

FLOOR GUARD is approved by the NSF as a general equipment and floor cleaner, but direct food contact equipment must be rinsed with potable water prior to reuse.

 

Logically, I guess you have currently been using option (a) (??). This would presumably have potential implications regarding re-use of dropped shrimp.

[sarah2014]

Hi Charles,

no we rinse the shrimp after it falls on the floor, we have a dedicated sink only for washing the shrimp that are picked from the floor

[sarah2014]

I attached a copy of the floor guard that we use