HTST Flash Pasteurizer Corrective Action

We use an HTST Flash Pasteurizer to treat soft drink syrups prior to filling on a Bag in Box Filler.

The system is set up to re-circulate the syrup into the balance tank if the temperature drifts below the critical limit.  It will not go back to forward flow until the temperature reaches the critical limit or above.  

The temperature and timing pump speed (which correlates to the time duration of the flash pasteurization) are recorded on a chart recorder.

The system is set to not produce non-conforming product.  However, we all know that nothing is foolproof.    

I am having a difficult time determining how to set up the corrective action wording.  Any help would be appreciated.

Thank you.

Would something like this work?

Automatic flow diversion back to balance tank if pasteurisation is <xx°C. Should divert fail, production will stop, any product which is deemed to be insufficiently pasteurised will be repasteurised (if this is possible) or disposed of.

This is pretty typical setup for dairy plants with continuous pasteurizers.  Basically, your controls should be equipment related and part of the process.  It should not be manual, this is regarding the temperature AND the flow rate.

So you mentioned how the system reacts when temperature CL is not achieve, but what about flow rate?  How is that controlled?

Also consider, can the controls in place be tampered with or adjusted?  If so, by whom and how?  Is it easy, difficult, or are there prevention measures in place to limit tampering or adjustments to the controls?

I have attached a HACCP Summary from the PMO.  It would be similar for your product.

Oops forgot the attachment.  Here it is.