Primus-Is testing of blown (not compressed) air required for HACCP?

I understand that testing of compressed air is a necessary Operational PRP. However, I am unclear about the need to test blown (not compressed) air. The specific situation involves blown air that is used to direct the movement of cut greens on a harvest and packing line. Testing of compressed air is a well established O-PRP; but a client opines that regular filter changes on the blown air intake manifolds are sufficient and testing is not necessary, because the air is not compressed. I'm helping the client to prepare for a GFSI audit, and am wondering if there is a standard response to this condition. Thanks in advance for any advice or info you can give!

I understand that testing of compressed air is a necessary Operational PRP. However, I am unclear about the need to test blown (not compressed) air. The specific situation involves blown air that is used to direct the movement of cut greens on a harvest and packing line. Testing of compressed air is a well established O-PRP; but a client opines that regular filter changes on the blown air intake manifolds are sufficient and testing is not necessary, because the air is not compressed. I'm helping the client to prepare for a GFSI audit, and am wondering if there is a standard response to this condition. Thanks in advance for any advice or info you can give!

 

Hi RS,

 

No idea why testing compressed air should be an oprp.

 

Usual question - Is any particular FS Standard involved ? They tend to differ in requirements.

Hi,RSanderson.

 

What standards or "norms" that states testing of compressed air is an established oPRP? Understand that contaminants are more concentrated in air becuase they are "compressed", but I think it should be managed by PRP.

Hmm, perhaps a misunderstanding of PRP vs oPRP. I thought the later pertained to a specific control point, which application of compressed air would be. I’ve read some articles that suggest compressed air should be CCP. Perhaps if it is coming from a central compressor though multiple lines then that qualifies it as just PRP? Feel free discuss!...I would learn something I’m sure. But I also don’t want to get into the weeds. My main query is whether blown air requires testing. The stsndard in question is PrimusGFS. There is a specific question in the GMP section regarding compressed air testing. It doesn’t speak to blown air, however. I’m wondering how to approach that from standpoint of HACCP..

On my experience, we dont actually measure blown air quality for the reason that blown air for conveyance are also coming from the same room, we just ensure that the air handling unit for the room and the blower fan is fit for purpose (meaning hygienic design , fitted with the right filter). From the product where this is used, risk assessment were made on its susceptibility of cross contamination coming from environment.  

Into the weeds indeed. 
Compressed air, by nature, may have oil and/or water in it, which brings up some hazards that have to be risk assessed and mitigated.

 

"Blown air", I am assuming is just ambient air that is "circulated" by fans or what not. If so, one would assume you test your ambient air. And you keep your fans clean.

 

It all depends on what food safety standard you are audited against. BRC specifically states "compressed air" as something that needs to be monitored. 

I can't imagine how you would determine how ambient air, blown around by fans would be an issue, unless you are a hyper high risk facility.

 

Marshall

Hi RS,

 

I presume you are referring to this section –

 

2.30     Testing/Analysis Records

 

a.   There should be records of routine equipment and environmental microbiological testing.

b.   There should be at least annual microbiological tests on water used in the facility (sampled

from within the facility) and (at least) an annual microbiological test for in-house produced

ice or a letter of guarantee from external suppliers of ice.

c.   Routine tests should be performed on compressed air that is used directly on food and

food contact surfaces.

 

 

According to sub-clause (a) seems you are anyway obliged to do micro. testing of environment which may/may not include air ?  

 

The Primus haccp system appears somewhat "generic" (eg unspecified to Codex , ISO, etc). It  does mandate a hazard analysis including likelihood/severity assessment.

 

 “Blown” air appears to cover a variety of equipment styles, eg –

 

https://www.aircontr...compressed-air/

 

haccp significance (if any) of the “blown air” is presumably with respect to contamination potential. For air supplies the latter is typically related to factors like purity, direct contact, RTE food, etc (similar compressed air).

 

Difficult to predict much more IMO without direct experience and/or more knowledge of the Process (esp. "Blower") and Primus.

 I will piggyback onto this thread...

what about regenerated nitrogen?this is where you use compressed air to generate nitrogen onsite(goes through 4filters..with sterile filter being last one)..nitrogen is stored in tanks and used in plant..longest piping from generator to point of use is about 600m away, piping is pvc..

Do I need point of use filters?

Hi, Dr. Vu.

 

It will be hard without the process flow and the usage, but if it follows the same process as compressed air, it may be necessary. As you also compress the air (to generate nitrogen) it is possible that condensation may also happen (if dewpoint is not controlled). In such cases especially if SS not in used (I assume this is always the case), then generation of moisture and physical material is possible.

I’ve been through 9 Primus GFSI audits at a produce packing house. We use blown air as a cooling and drying mechanism. Our auditors require that the cooling step be part of the HACCP plan, but they’ve never expected or commented on testing the air. Our recent audit by the state on behalf of FDA recommended testing the air from the blower over the wash line.

 

I’ve been through 9 Primus GFSI audits at a produce packing house. We use blown air as a cooling and drying mechanism. Our auditors require that the cooling step be part of the HACCP plan, but they’ve never expected or commented on testing the air. Our recent audit by the state on behalf of FDA recommended testing the air from the blower over the wash line.

 

Hi cindy,

 

Thks for input.

 

It sounds like FDA may have "analogised" yr blowing set-up to compressed air. I'm curious how they expected you to test the air ? APC/Y&M ?

 

Unfortunately OP's method of (transport) blowing (eg risk-free ?) is unknown. How do you do it ? Centrifugal blower ?

Charles, FDA suggested testing Y&M. It's a fan.

Charles, FDA suggested testing Y&M. It's a fan.

 

Yeah, so they provided no standard nor any testing that would indicate a potential FS issue.

 

Sounds like you may test something to placate this particular auditor, but then move back to regular practice unless they come back with an actual standard vs auditor opinion.

Yeah, so they provided no standard nor any testing that would indicate a potential FS issue.

 

Sounds like you may test something to placate this particular auditor, but then move back to regular practice unless they come back with an actual standard vs auditor opinion.

 

Hi 3F,

 

Yes, I guess these are intuitive reactions in the absence of specific Guidelines.

 

Evaluation of potential microbial contamination of air for non-aseptic scenarios is, afaik, "subjectively interpretive ", eg -

 

microbial contamination - iso8573-7.pdf   879.78KB   25 downloads

 

And, afaik, Y&M falls into the same bucket.