6 replies to this topic

[Sabear]

​I work at a low-risk facility (RAW one ingredient). We do not have any CCP's. When looking at the PC for FSMA. It talks about for every preventive control identified to have: monitoring, corrective action, verification, supply chain, and record review.
 
So if I list Supply approved only program for incoming packaging materials as a PC measure, does that count as a PC? We currently require them to send us their audit findings. I am unsure/lost as to how to apply the other requirements(?)
 
If someone could provide me with an example, that would be excellent.

[FurFarmandFork]

What product?

[Sabear]

Raw Peanuts

[FurFarmandFork]

Okay, so what process flow? Are you a harvester/packer, do you remove foreign material, do you shell them?

 

A process flow would help us evaluate for any possible preventive controls. Keep in mind the categories

Supplier

Process

Sanitation

Allergen

 

If you previously had no CCP's then you likely have no "process" controls if the product is raw. Though I wonder if you sort for rocks/dead rodents/etc to meet customer specs that might be worth including. Your call.

I would worry about mixed allergens potentially from peanut farmers (cross contamination with other nuts) that would be a simple supplier control for the peanuts, you may also have specifications for mold or aflatoxin that would be a supplier or inspection control?

If your product is truely raw and expected to be essentially "contaminated", not sure why you would worry about the packaging other than it being fit for food, which is a supplier program but not necessarily a supplier PC.

Finally, make sure you include a food fraud component in your food defense plan, as country of origin fraud is a known issue in peanuts.

[Sabear]

Process flow 

receiving -> storage -> sticks/stones removed -> hulls removed -> product separation (splits from whole kernel) -> automated eyes to remove damaged peanuts/foreign material -> visual inspection -> sizing -> totes being filled -> storage ->distribution 

We have to pass DA grades which test for aflatoxin, foreign objects etc. If we fail we rework or downgrade it to nonedible.

 

We shell them

[FurFarmandFork]

I would see these PC's from that flow (Keep in mind I don't do raw ag, so industry standard may be different). I think we have some nut folks on the forums so if you give it a few days they can probably weigh in.

 

Hazard: Foreign material in product (shell remnants, rocks, metal), biological vectors such as pests

Process preventive control: automated eyes to remove foreign material

Validation: manufacturers specifications and/or initial testing in your facility

Monitoring: visual inspection downstream constantly verifies eyes are working as intended I assume, or your startup/periodic check for function

Corrective action: up to you, likely fix the eye and rework the product.

Verification: End item inspection or your startup/shutdown check for function (put something through and make sure it's rejected, similar to metal detection verification)

Records: Checks recorded per lot and reviewed by another person

 

Hazard: Aflatoxin

Supplier preventive control: Product moisture content or specification for % moldy peanuts? Out of my industry here

Validation: Supplier review, initial testing of supplier source peanuts, industry publication for moisture standards to avoid mold

Monitoring: Inspection at whatever point makes sense e.g. receipt.

Corrective action: Reject lot or divert to lower grade/non-edible

Verification: end item checks and grading

Records: Records of inspections

 

You may also have another control if you rely on any sort of temperature/humidity requirements in storage to keep mold from forming in either bulk storage or final product storage.

 

I highly recommend taking a PCQI course from FSPCA to help fulfill "qualified individual" requirements.

[Sabear]

Thank you so much FurFarm.

We do not control temp or humidity of stored peanuts. And will be taking the PCQI course this summer, which doesn't really help me right now. So I appreciate any and all input. We do test for aflatoxin before receiving peanuts as well as before they are ready to be shipped out. Thank you so much.