Handling of Potentially unsafe products Clause 7.10.3.2

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Handling of Potentially unsafe products Clause 7.10.3.2

Started by Ayuse, Jul 20 2018 09:50 AM

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Ayuse

IFSQN Active

2 Replies

20 July 2018 - 09:50 AM

Hello brilliant minds,

Please provide me clarity on this clause;

Evaluation for release

Each lot of product affected by the nonconformity shall only be released as safe when any of the following

conditions apply:

a) evidence other than the monitoring system demonstrates that the control measures have been effective;

b) evidence shows that the combined effect of the control measures for that particular product complies with

the performance intended (i.e. identified acceptable levels as identified in accordance with 7.4.2);

c) the results of sampling, analysis and/or other verification activities demonstrate that the affected lot of

product complies with the identified acceptable levels for the food safety hazard(s) concerned.

I work for a seasonings/flavor blending company that utilises salt as a major ingredient, MSG, herbs & spices in descending order.

Our expiry dates are 1 year old and many times, slow moving products expire while at dry, ambient storage.

Is it possible to release a dry seasoning blend (past expiry date) back into production and rework into a larger batch say (5kg in 1000kg) without sending a product for micro evaluation to an external lab?

We will of course do an organoleptic report to verify quality of the product, review C.O.A's (to ensure ingedients used for the blend are still within expiry date) and add the production record to show control during blending. Will this suffice? :uhm:

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Scampi IFSQN Fellow · Answer 1 · 2018-07-20T13:58:31+00:00

ok, that clause basically means that you cannot rely solely on the monitoring records when the product was produced.

So you couldn't say, well the CCP was within limits so even though its xxxx, we will release it

If product has expired, it should NOT go back into rework.......that should have happened while there was still viable shelf life...............that may constitute "adulterated product"

You get to determine shelf life, so maybe focus on shelf life extension and production volumes instead of an after the fact work around

I am not saying micro is an issue, but rather how potent the flavour profile is and customer satisfaction levels as a result of blending expired product back in

SQFconsultant IFSQN Fellow · Answer 2 · 2018-07-20T17:01:09+00:00

"Is it possible to release a dry seasoning blend (past expiry date) back into production and rework into... "

Answer: NO!

Handling of Potentially unsafe products Clause 7.10.3.2

Ayuse

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Scampi

SQFconsultant

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