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What Would you Do? - Whey Powder Recall

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Xoinks

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Posted 23 July 2018 - 05:07 PM

We've been watching the spreading recall from the whey powder with Salmonella.  

 

Some items, like bread and swiss rolls have been recalled.  The bread especially catches my attention - as I assume (And acknowledge I don't know for sure) the powder is baked in and not used after the kill step. (There is also a Ritz recall that seems to be centralized on anything with a cheese filling - so that I would assume may not have been subjected to a kill step)

 

http://corporate.pub...fashioned-bread

 

So looking for opinions.  If the assumption is true, and the whey powder was used in a product prior to being subjected to a validated kill step, is it best practice to still recall the finished product it was used in?  Or would you trust your kill step?

Just looking for opinions and thoughts on this.   I personally lean towards trusting the kill step provided I am confident that my flow process eliminates any risk of cross contamination between raw and finished.  



mgourley

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Posted 23 July 2018 - 06:33 PM

I would agree that if you have a validated kill step, and have the documentation and production records to back it up, if you used this lot of product you have done your due diligence.

 

Just to recall things "because" is not a good idea.

 

Marshall



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SQFconsultant

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Posted 23 July 2018 - 08:03 PM

Have seen way too companies issue a recall to err on the side of safety, but gee whiz that is an expensive and potentially brand damaging way to go about things.  I think your due diligence on this will pay dividends in not jumping into the fray and ensuring as Marshall said to have all your documentation, backup, etc.


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Posted 25 July 2018 - 09:03 AM

Would based my decision on the confidence that I have validated and verified the right control measures. If the control measures (kill step) is demonstrated to be effective then would not necessarily recall. May also do sampling of the products produced to further demonstrate due diligence.

 

However, what may be lost here is that the consideration on the transport of material from warehouse to addition point. Sometimes on these cases, this part is not being considered only to be surprised during environmental monitoring for pathogen that an S positive is isolated.  Hence, the statement of "verified the right control measures".



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Posted 25 July 2018 - 11:47 AM

Would based my decision on the confidence that I have validated and verified the right control measures. If the control measures (kill step) is demonstrated to be effective then would not necessarily recall. May also do sampling of the products produced to further demonstrate due diligence.

 

However, what may be lost here is that the consideration on the transport of material from warehouse to addition point. Sometimes on these cases, this part is not being considered only to be surprised during environmental monitoring for pathogen that an S positive is isolated.  Hence, the statement of "verified the right control measures".

 

Hi 012x

 

i should add that I am unaware of the details surrounding this recall.

 

Are you suggesting either airborne penetration of a packed product or self-contamination by the receiver ?


Kind Regards,

 

Charles.C


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Posted 26 July 2018 - 12:58 AM

Hi, Charles.

 

Self contamination with the receiver. It is with the assumption that the "contaminated" bag is used. While heat treatment, if validated properly is sufficient for mixed materials, what I am mentioning is the people who performed the tipping of "contaminated material" or flow of waste , etc.. may spread further contamination in the area. Hence, verified the right control measures.



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Posted 26 July 2018 - 07:21 AM

We've been watching the spreading recall from the whey powder with Salmonella.  

 

Some items, like bread and swiss rolls have been recalled.  The bread especially catches my attention - as I assume (And acknowledge I don't know for sure) the powder is baked in and not used after the kill step. (There is also a Ritz recall that seems to be centralized on anything with a cheese filling - so that I would assume may not have been subjected to a kill step)

 

http://corporate.pub...fashioned-bread

 

So looking for opinions.  If the assumption is true, and the whey powder was used in a product prior to being subjected to a validated kill step, is it best practice to still recall the finished product it was used in?  Or would you trust your kill step?

Just looking for opinions and thoughts on this.   I personally lean towards trusting the kill step provided I am confident that my flow process eliminates any risk of cross contamination between raw and finished.  

 

As i understand the panic in USA is amplified by the (apparently legitimate) non-disclosure of source of alleged (!?) contaminated whey powder ?.

 

So much for "Validation" and using implemented traceability data to assist recalls ?

 

http://www.foodsafet...almonella-risk/

 

Perhaps sometimes "Ignorance is not Bliss"

 

So my initial response to OP would be to attempt to minimise the "Ignorance".


Kind Regards,

 

Charles.C


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Xoinks

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Posted 26 July 2018 - 06:59 PM

Thank you for the thoughts and contributions, everyone.   Thankfully we are as of yet not impacted by this recall, but unfortunately never know when the next one might be around the corner.   I appreciate this forum and the opportunity to bounce questions off of a wider group of professionals. 



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Posted 27 July 2018 - 09:03 PM

Thanks for the post, was wondering about this myself.  The company issuing the recall, if I understand correctly, had a batch of whey that tested positive but had not been released from testing hold.  They went ahead and issued the recall for additional product that had been released after testing negative.  So seems like very little risk in these recalled product then made with kill step before consuming.  Is it safer for your brand to issue a recall when not fully necessary or to not issue a recall when an extremely remote chance of risk exists that might blow up if realized?  As a person who, and working for a company and industry that, is concerned about wasted food, seems sadly wasteful.  Could it be that the source of contamination may further have resulted in quality issues too?



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Posted 28 July 2018 - 12:02 AM

In the case of the Pepperidge Farms Goldfish stuff,,,,the whey would have been applied as part of the seasoning after a kill step, so you pretty much have to recall there.

Did PF really want to do that? Probably not, since the average consumer is only going to hear "Goldfish crackers", not "a supplier of materials used to make Goldfish Crackers"

 

Then again, a company that large is really not going to take a large financial hit, because they pay for recall insurance.

 

It's a tough call.

 

Marshall





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