Jump to content

  • Quick Navigation
Photo

SOP's, WI's, oPRP's, CP's, PoA

Share this

  • You cannot start a new topic
  • Please log in to reply
34 replies to this topic
- - - - -

Scampi

    Fellow

  • IFSQN Fellow
  • 5,444 posts
  • 1507 thanks
1,524
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 18 October 2018 - 02:22 PM


Please stop referring to me as Sir/sirs


Scampi

    Fellow

  • IFSQN Fellow
  • 5,444 posts
  • 1507 thanks
1,524
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 18 October 2018 - 02:27 PM

I've added some comments on your HA........please bear in mind I am not BRC!!

 

 

I'm also a huge fan of this database

http://www.inspectio...9/1384900941583

 

It is a bit tricky to use in the beginnig, but aligns with Codex HACCP from incoming product, process steps etc

Attached Files


Please stop referring to me as Sir/sirs


Conference_pear

    Grade - Active

  • Newbie
  • 20 posts
  • 1 thanks
1
Neutral

  • Earth
    Earth

Posted 18 October 2018 - 06:27 PM

Scampi, 

 

Thank you so much for your comments! Concerning your remarks… they are well noted and a lot of things are indeed implemented. We have a very thorough pest control implemented by an external company and all our internal lights are indeed shatterproof. We have an approved supplier procedure with a risk asssessment on each supplier, since some of them have a combined farm with vegetable and thus possibly pose a threat on allergens. In our facility we have a very strict closed door policy and all gates have a buffering zone so  that there is never a direct passage to any vulnerable area or material.

 

Indeed I should rely more on GAP's at farm level but my experience with farmers has taught me differently. 



Scampi

    Fellow

  • IFSQN Fellow
  • 5,444 posts
  • 1507 thanks
1,524
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 18 October 2018 - 06:30 PM

Scampi, 

 

Thank you so much for your comments! Concerning your remarks… they are well noted and a lot of things are indeed implemented. We have a very thorough pest control implemented by an external company and all our internal lights are indeed shatterproof. We have an approved supplier procedure with a risk asssessment on each supplier, since some of them have a combined farm with vegetable and thus possibly pose a threat on allergens. In our facility we have a very strict closed door policy and all gates have a buffering zone so  that there is never a direct passage to any vulnerable area or material.

 

Indeed I should rely more on GAP's at farm level but my experience with farmers has taught me differently.  LOl  I hear you on that one!!  Fortunately for me, the farm owner here sat on the board that helped get CanadaGap up and running


Please stop referring to me as Sir/sirs


Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 18 October 2018 - 08:01 PM

Hi koen,

 

Thks for posting yr haccp plan. I had a quick browse through. It's obvious that a lot of work has gone into it. I generally liked the basic format with the exception of the Q1,Q2 etc but the latter is amazingly popular despite IMO its not being neccessary.

 

I am a little confused. Is this targetted towards BRC8 or Global Gap ? or ?

(it's not my area but I thought that Global Gap was primarily a pre-Packinghouse Standard and that PackingHouses tended to go more towards something like Primus rather than BRC).

 

I can only speak for BRC7.

 

IMO there are some fundamental deficiencies in the haccp plan. However this comment may be different for another FS Standard.

 

A few  examples - 

 

(1) the consequence of food being contaminated with pathogenic bacteria is stated as "moderate". Admittedly this can relate to the specific species (unmentioned) involved and level of contamination but low levels of such as Salmonella, E.Coli O157 have killed people. That is why they are zero-tolerant.

 

(2) It is illogical to set an acceptable level of  every conceivable form of Physical/Microbiological contamination as  "Nil". It just isn't realistic.

 

(3) A BRC7  haccp plan does not have a quality section(s). It's implemented for Safety. (A BRC risk assessment might though despite the overall standard being labelled as "Safety").

 

(4) Some of the allergen hazards look a little "far-fetched".

 

Despite comments like the above, I can anticipate that the presentation would maybe satisfy some FS Standards. I wondered if it derived from an established template ?


Kind Regards,

 

Charles.C


Conference_pear

    Grade - Active

  • Newbie
  • 20 posts
  • 1 thanks
1
Neutral

  • Earth
    Earth

Posted 19 October 2018 - 07:26 AM

Hi Charles,

 

Thanks for your feedback. For now it is targeted on BRC 7 and IFS 6. The Global GAP focusses on the whole supply chain, this means that a grower who has implemented also the packing and storage in his scope is audit for the entire supply chain. So the fruit we receive can come from our own growers GG certified for only the growing part or from growers certified for the whole scope and we also buy from independent growers or at auction from other co-operations. Since we deliver every market in EU, UK we are requested to have multiple certificates. I know primus from my work in IQF, but here in EU it's not well known. At the moment we are certified according BRC (unnanounced!), IFS, QS (Germany), Global GAP + addon GRASP, SMETA, Field to Fork, TNC (Tesco) and later on today I 'm having an audit by Carrefour who have their own standard. Not easy to please everyone.

 

I got the remark on the quality issue from a BRC auditor from SGS, that I really should implement it in my HACCP study. For example shelf life testing... we pack apples and pears, we don't cut them, don't cook them, just store, pack and ship them. Not all batches of fruit tend to have the same storage properties due to minerals in the soil, residu's, post-harvest treatment. So you think we should perform a few general shelf life tests at the beginning of the season and after 2 of 3 months and again at the end of the season (june-july) for the last volumes. Keep in mind the cold stores are monitored automatically for CO, O2, temperature and moisture.

So a few years ago we had an auditor who implied that we should perform a shelf life test for every product from every batch that runs of the line. After consultation, we built a shel life lab (80 m2) with special climate control where we store from every batch graded a sample for 2 weeks and from that batch we pack into sometimes upto 10 different packaging. So from every finished packaging we put a sample in shelf life. And that every day... we had to adapt our system to manage all this data... So very time and money consuming! Therefor I want to convince my supervisor to re-evaluate all these processes in our company, implement a new well built quality system which could save us, time and money.

 

Concerning your remark on the micro hazard; what are your thoughts on the values below?

 

General Germs  < 5.105

 

Enterobacteriaceae <1.103

 

E.Coli <1.102

 

Moulds <1.104

 

Yeasts <1.104

 

Staphylococcus aureus <1.102

 

Listeria Absent / 25g

 

Salmonella Absent / 25g

 

Your comments are very much appreciated and I will surely implement your remarks. And yes I got the format from a existing template.



Scampi

    Fellow

  • IFSQN Fellow
  • 5,444 posts
  • 1507 thanks
1,524
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 19 October 2018 - 12:36 PM

What?????????? Shelf life on fresh fruit............are you joking!!   There are way too many variables involved to ever get repeatable data and therefore it's moot to do (IMHO)

 

There is a reason produce is auctioned at food terminals...........the faster it can get to market, the higher the value!!!  I am blown away by this

 

We would never try and perform shelf on our field crop..........which field, water content, hours since harvest, outside weather on harvest day, time to packhouse, time to cooler.....I could go on and on and on

 

(clearly I'm not a member of the EU however and I gather they have complicated things dramatically)

 

Under which GFSI did the auditor speak to shelf life?

 

I really wouldn't think spending that kind of money for shelf is a determination of QUALITY. I would be targeting things like bruising (reduction strategies) under/over ripe as a % of a lot, a targetable reduction in chemicals used (there are a lot of options when it comes to applications in all kinds of crops, introduction of good bugs (true lady bugs, nemotodes etc)


Please stop referring to me as Sir/sirs


pHruit

    Grade - FIFSQN

  • IFSQN Fellow
  • 2,071 posts
  • 849 thanks
536
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 19 October 2018 - 01:16 PM

The EU is pretty sensible on this IMO - there is no obligation for shelf life ("date of minimum durability") labelling on fresh produce. From Annex X of Regulation (EU) 1169/2011:

1(d) subject to Union provisions imposing other types of date indication, and indication of the date of minimum durability shall not be required for:

- fresh fruit and vegetables, including potatoes, which have not been peeled, cut or similarly treated; this derogation shall not apply to sprouting seeds and similar products such as legume sprouts,

 

A lot of bagged fresh produce does seem to have a BBE on it, at least in the UK, although there are more discussions now about intentionally ceasing doing this as it leads to lots of people throwing away perfectly good food due to the poorly understood distinction between "use by" and "best before" dates (and an apparent near-total loss of consumers' ability to look at fruit/veg and decide if it's edible or not...).

 

 

@Conference_Pear:
Depending on how you're going to be characterising these micro hazards, you may want to consider separating out spoilage/indicator organisms from pathogens as the latter would be the ones of primary interest in a HACCP risk assessment focussed strictly on safety.



Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 23 October 2018 - 03:52 AM

Hi Charles,

 

Thanks for your feedback. For now it is targeted on BRC 7 and IFS 6. The Global GAP focusses on the whole supply chain, this means that a grower who has implemented also the packing and storage in his scope is audit for the entire supply chain. So the fruit we receive can come from our own growers GG certified for only the growing part or from growers certified for the whole scope and we also buy from independent growers or at auction from other co-operations. Since we deliver every market in EU, UK we are requested to have multiple certificates. I know primus from my work in IQF, but here in EU it's not well known. At the moment we are certified according BRC (unnanounced!), IFS, QS (Germany), Global GAP + addon GRASP, SMETA, Field to Fork, TNC (Tesco) and later on today I 'm having an audit by Carrefour who have their own standard. Not easy to please everyone.

 

I got the remark on the quality issue from a BRC auditor from SGS, that I really should implement it in my HACCP study. For example shelf life testing... we pack apples and pears, we don't cut them, don't cook them, just store, pack and ship them. Not all batches of fruit tend to have the same storage properties due to minerals in the soil, residu's, post-harvest treatment. So you think we should perform a few general shelf life tests at the beginning of the season and after 2 of 3 months and again at the end of the season (june-july) for the last volumes. Keep in mind the cold stores are monitored automatically for CO, O2, temperature and moisture.

So a few years ago we had an auditor who implied that we should perform a shelf life test for every product from every batch that runs of the line. After consultation, we built a shel life lab (80 m2) with special climate control where we store from every batch graded a sample for 2 weeks and from that batch we pack into sometimes upto 10 different packaging. So from every finished packaging we put a sample in shelf life. And that every day... we had to adapt our system to manage all this data... So very time and money consuming! Therefor I want to convince my supervisor to re-evaluate all these processes in our company, implement a new well built quality system which could save us, time and money.

 

Concerning your remark on the micro hazard; what are your thoughts on the values below?

 

1. General Germs  < 5.105

 

2. Enterobacteriaceae <1.103

 

3. E.Coli <1.102

 

4. Moulds <1.104

 

5. Yeasts <1.104

 

6. Staphylococcus aureus <1.102

 

7. Listeria Absent / 25g

 

8. Salmonella Absent / 25g

 

Your comments are very much appreciated and I will surely implement your remarks. And yes I got the format from a existing template.

 

Hi koen,

 

Sorry delay. Flu attack.

 

Thks yr comments. Yr audit schedule demonstrates the typical failure of GFSI's concept of one Standard for All.

 

I have zero experience raw fruits. For BRC, IIRC the requirement for shelf life is to demonstrate a continuous ongoing system of shelf life validation. This means that "sampling" is permissible. In my area (raw frozen seafood/long shelf lives) the usual approach involves maintaining a few products under prolonged evaluation with monthly quantitative OLQ and micro. But this depends on one's criteria for the labelled shelf life and the variations found in the actual product testing.

IMO you have received some rather poor auditorial advice.

 

Re - Micro, I assume this is a set for yr finished product.

Note that items 6-8 are the only explicit safety hazards although "Listeria" should probably specify L.monocytogenes. Pathogenic E.coli is one maybe significant omission.

Note that "absent" is more meaningfully stated as "Not detected" although some customers may not agree.

The micro values (assuming cfu/gram) are fairly typical "raw" target levels afaik although IIRC ICMSF (ultimately) declined to offer micro.limits for raw fruits in their much-referenced compilation due the magnitude of the natural variation. Again, customers may disagree.

The only, probably, non-argumentative safety micro. comment is that one would expect the product meets spec 8. rewritten).

IMEX it would be unlikely that a raw product routinely complied with spec 7.


Kind Regards,

 

Charles.C


Conference_pear

    Grade - Active

  • Newbie
  • 20 posts
  • 1 thanks
1
Neutral

  • Earth
    Earth

Posted 14 December 2018 - 08:20 AM

To everyone who provided any input in this subject, I would like to say thanks!

 

 

Last week my food safety manual and implementation was put to the test during a two day BRC audit.

 

We passed with 4 minor remarks!!

 

Once again thanks to everyone for your feedback. It helped me to look at things from a different perspective!





Share this

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users