Is micro testing of PRPs/services /low risk foods required?

Hi all,

I am working in a company which produces edible oils, fat emulsions and milled corn grains.

We are into ISO 22000:2005. During our pre- assessment with a certifying body, microbial analysis/ monitoring is one of the findings.

Based on FDA- our products belong to the low risk food category, foods that are unlikely to contain pathogenic microorganisms and will not normally support their growth because of its characteristics and are unlikely to contain harmful chemicals. However, we do annual microbial test for finished product as monitoring through third party laboratory analysis. But, we do not have microbial tests on food contact surfaces, compressed air we are using to blow impurities from our packaging materials, and other cleaning validation.

My question is, do we really need to tighten our monitoring in terms of microbial test? Like the frequency of daily for our products? Or every start up/ shutdown for our machines and equipment?

At the moment, we do not have a micro laboratory.

Thanks :-)

Dear Cholah35

The annual monitoring you are doing  of the finished products should be enough. I just you also include monitoring of food contact surfaces  once a month for few months to show that your cleaning procedures are working and have been validated.

On services such as compressed air you can adopt the similar approach i.e monitor the microbiological quality of the regularly may be once a month to show that compressed air continuously meets the microbiological standard.

Kind regards

Dr Humaid Khan

Managing Director

Halal International Services

Beverly Hills Australia

Hi cholah,

Not a user of iso2200 but can make a few comments which users are welcome to correct if in error -

(1) I deduce yr products are partly/totally RTE. If so, compressed air facilities directly/indirectly contacting food/fcs are not necessarily  themselves  regarded as "Low Risk".

(2) Regarding "services" I suggest you examine iso22000/para.7.2.3. The latter is currently often responded to via iso22002-1.

(3) Assuming you regard "cleaning" as a PRP, afaik validation of the program's effectiveness is not required by iso22000/22002-1. Verification is. Afai can see, iso22002-1 does not specifically mandate a necessity to use micro.data for verifying the effectiveness of the cleaning/sanitizing program (11.1/11.5). But it does for the air (para 6.4). (Nonetheless IMEX micro.data is very effective  for verifying cleaning/sanitizing programs albeit at a not insignificant effort/cost, especially if it needs to be outsourced).

(4) A conventional micro.lab. would probably have to invest for sampling/monitoring compressed air. Not impossible but most facilities seem to outsource if their setup only needs routine monitoring.

(5) micro.testing of finished products is typically part of the haccp verification program. Frequency usually "risk-based"/financial  + logistically if in-house lab..

 

 

Based on FDA- our products belong to the low risk food category, foods that are unlikely to contain pathogenic microorganisms and will not normally support their growth because of its characteristics and are unlikely to contain harmful chemicals.

Be careful on this, the landscape is changing. Just because your product doesn't normally support the growth of pathogens does not mean it is lethal to them. FDA also takes the position that flour is not RTE and tells consumers it should not be eaten raw, however the flour manufacturers involved in the recent E. coli outbreaks in Canada and USA (or cookie dough for listeria) are still being held liable for producing contaminated products. It looks like many of your products get used downstream, if your material is the "seed" source for pathogens that will proliferate downstream, you're still going to receive the liability at some point.

Hello, I'll address the compressed air portion of your question. FDA and certifying bodies like SQF, BRC, FSSC22000 require monitoring of compressed air for chemical and microbial contaminants. Chemical contaminants that can be present in a compressed air system are particles, water, and oil. We just presented a Food Safety Friday webinar that may be helpful to you, here's the link: https://goo.gl If you have any specific questions, feel free to contact us at IFSQNanswers@AirCheckLab.com, 512-263-0000 x4.