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Requirements for wet ice and dry ice in low risk operation

sqf ice potability processing aid ingredient 11.5.3 11.5.4 dry ice traceability

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#1 TJW

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Posted 29 January 2018 - 04:23 PM

Low Risk Operation - SQF Edition 8

​11.5.3 and 11.5.4

 

Wet ice is purchased and added to offal products in our slaughter operation.  We test the wet ice for potability and have a letter of guarantee on file from the supplier.

1) Would the wet ice be considered an ingredient or a processing aid?

​2) Do we need to maintain traceability on the wet ice?

3) Should we be receiving COA's for each lot of wet ice?

 

We make dry ice and it is added directly to product to cool it down (examples are offal and hams).

​1) Do we need to test the dry ice for potability?  How would we go about this?    

2) Would the dry ice be considered an ingredient or a processing aid?

 

Thank you in advance for sharing your expertise.

 

 



#2 FurFarmandFork

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Posted 29 January 2018 - 05:36 PM

Wet ice:

1. Ingredient vs processing aid, consult with your inspector? If the water is ultimately removed from the offal, then processing aid, if it becomes part of the final product, then ingredient. E.g if I add ice to cool soup, ingredient, if I add ice to cool chicken breasts then remove them from the water bath, processing aid.

 

https://www.fsis.usd...pdf?MOD=AJPERES

 

2. Yes, I would maintain tracebility, if they recall the ice upstream for a pathogen, you don't want to have to recall everything you've ever made, do you?

 

3. No, you don't need a CoA for every lot. Just like any other ingredient, the need for a CoA is dependent on your risk analysis. I would consider ice to be low risk and wouldn't require one. You should independently verify micro just like you said you do already.

 

 

Dry Ice:

I don't think you need to test it for potability, make sure the Co2 you use is food grade purity. Hard to imagine this as a source of contamination.

2. In this case I would say processing aid since the Co2 will gas off and not become part of the product (it isn't carbonated I assume :) ). See link above or call LPDD to get a determination.


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#3 TJW

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Posted 31 January 2018 - 03:05 PM

The wet ice does not come with a lot number.  Should it?

 

I want to be sure that we are meeting the expectation of the SQF Standard.



#4 FurFarmandFork

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Posted 31 January 2018 - 03:23 PM

1. It should, depending on who the supplier is they need to code their stuff, but if they're super local and not required to, you can assign your own lot numbers based on the PO/delivery date and be able to trace backwards that way. Just either mark the bags or segregate them by delivery.


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#5 MusselsGalore

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Posted 17 October 2018 - 07:24 PM

We recently had our 3rd Party Audit.  We make our own ice and test our municipal water source annually.  We make ice chips that are dispensed into a clean and sanitary plastic liner within an insulated tote to be delivered to production areas throughout the company to maintain temperature control for freshly harvested shellfish.  We did not track the liners used to bag the ice by some lot code identification # and came up as a non-compliance item.

 

So while the ice was okay, the liners holding the ice would be subject to recall?  I contacted the manufacturer about lot code identification for the rolls of liners we source from them.  Lot Codes were available but they were surprised to find out that the ice tote liners were part of our traceability program.  

​As a result we now track the liners used to make ice.  These liners do not make up the finished product packaging (primary or secondary).  If the ice is considered a processing aid, is the liner included and therefore must be traceable?



#6 Scampi

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Posted 17 October 2018 - 07:43 PM

Unfortunately yes, the liner should be included

 

Let's pretend for a minute here.........with ice in all likelihood nothing is going to migrate from the liner to the ice and therefore into your product

 

But the line goes down for an 1 1/2 hours and someone closed the liner, but didn't put the insulated lid on and you've got carcasses now sitting in water not ice. So the warm water allows a theoretical contaminate to travel from the liner to your cuts.......now they are adulterated and you didn't even know

 

ALL food contact surfaces that are disposable should be included in traceability. I'm also assuming you would use the same liner type to also ship in combos???


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