Bringing Poultry Bones into Co-Manufacturer
Hey all!
I run the FSQA department for a small business co-manufacturer that does high acid canning, craft soda production, and RTE sauces for small clients. Promoting and supporting local food producers is built into our company culture, alongside food safety. Recently, we were approached by a chicken broth company to make their product within our facility. This would be our first meat/poultry process. Last week my CEO, the broth company owner, and myself sat down with the state health department and the USDA. The consensus was that as long as the documentation was in place and approved, the final decision rested in our, the co-manufacturer, hands. The biggest fear the health department and I have is the increased risk and severity of cross contamination onto the production of our other products, especially our RTE sauces. If we decided to take this client, we would reserve a full week for production, remove everything from the production room that will not be used, and have two days to do a full clean (foam washing, equipment disassembly, air filter replacement, etc). Is this enough to significantly reduce the risk to our other FDA products? The three main factors to risk reduction for this production would be isolated time, isolated space, and increased sanitation. Unfortunately, the only equipment that would be reserved for this production is a convection oven. All other equipment (kettles, fill line, utensils) are also used in our other productions.
What are your thoughts?
I really appreciate your feedback!
Best,
Jackie
Hi JackieD -
Many plants in the US produce both USDA & FDA products (referred to as 'dual jurisdiction'). Since poultry is not considered an allergen, it sounds like your separation and cleaning procederes should be more than adequate.
Would the chix broth be RTE? Assuming that it is, I would strongly suggest that you spend time to go through the HACCP & SSOP requirements and expectations for the product on the FSIS website. They may sound similar to FDA's, but implementation is quite different. Realize that you must have FSIS inspection personnel available/on-site whenever you produce USDA-regulated product. This will increase your cost. Your plant will be amenable to Pre-Op inspection every day that you produce USDA product.
Although doable, this is not a project to jump into lightly. You need to spend the time to fully understand FSIS' requirements and how they differ from FDA's.
KTD
If the cleaning and segregation you do and you think its not enough, you can you lab/test strips to test for any residues for example protein since its chicken.
Are your concerns primarily microbiological? Is the chicken arriving cooked? If it's already been made RTE, it doesn't pose any more of a risk of contaminating your plant than any other ingredient really.
If your cleaning process addresses the hazard and the chicken doesn't become a source of environmental hazards (if cooked it should be free of Sal and Lis) then hop on board and get used to having an inspector on site for chicken days. :)