34 replies to this topic

[Conference_pear]

Hello everyone,

 

My name is Koen Vanoirbeek and I 'm responsible to maintain the food safety standard in a fruit packing facility. Not something very exciting, but with the new BRC 8 there is a need to rewrite our handbook. This is still based on the old ISO 9001 (installed years before I came to work in the company) and in dutch. The past 6 months I set myself to write a new handbook based on the BRC 8 (and in english).

 

I listed my PRP's, wrote my procedures and SOP's.

 

Based om my HACCP study I don't have any CCP's. We mainly pack apples and pears. They are harvested (Global GAP certified), stored in cold stores and packed in crates or boxes. But I do have a few control points:

 

- inspection of the fruit temperature at reception, after pre-cooling, during storage and after packing (before dispatch)

- water quality inspection (transport water and water to rinse the fruit; both potable water)

 

Now I want to set my terminology right.

 

After the HACCP study normally one makes a summary of the CCP's which form your HACCP plan? But if you don't have any CCP's, do you list your CP's? And should I call them CP's or Points of Attention? 

 

Same for the SOP's (standard operating procedures), shouldn't I call them WI's or oPRP's? I can't seem to find the correct logic explanation on this matter anywhere. 

 

Your help is much appreciated.

 

Kind regards,

 

Koen

 

 

[Scampi]

So since the temperature isn't a HARD stop (i'm assuming) and you have a bit of flexibility, that would be considered a Control Point......you are still monitoring it, but you're not out of compliance if you're 1 degree above your target temperature

 

I would argue that your water potability IS a CCP; what do you do if you have ZERO free chlorine??

[Conference_pear]

Hi Scampi,

 

Thanks for your reply! My first on IFSQN!

 

Well the potability is not an issue in our sector since we use tapwater and the communal services are responsible for its potability.

 

And chlorination... Not one single fruit packing facility in our region uses this type of process. I have thought about it and tested it. But the problem is that some residu's on the fruit (all far within MRL boundaries) are strenghtend by a chlorination process. Even at a concentration of 0.05 %. 

 

I have attended about 20 BRC audits and the issue with water use in fresh fruit handling is always covered by a PRP (cleaning, sanitation, …) and 1 chem. and micro analysis of the water a year.

[MsMars]

You probably don't want to strictly rely on muncipal sources for your potability validation data.  Are you doing any sort of testing on your water, especially if you aren't using chlorinated water?

[Scampi]

Agree with Ms Mars.......relying on the municipal testing ONLY tells you that the water WAS potable when it left the water treatment plant. You do not know that it is ok within your facility

 

There is a requirement that water be checked at least monthly (I mange 6 onsite audits per year, 2 of them for fresh produce) and we still check the water monthly for potability

 

But back to terminology, I do not like WI etc etc

 

An SOP was an SOP long before this terminology came around. Use the verbage that makes sense for you...........as long as the first step is applying basic HACCP principles.

 

Oh, and just because NO ONE IS doesn't mean that you shouldn't explore options.......chlorine is not the only wash water chemical out there, PAA reacts very differently. What residues in particular are you concerned with?

 

 

Out of curiosity, why have you listed receiving temperature as a control point and what would you do about it if the fruit was too warm?

Edited by Scampi, 17 October 2018 - 01:55 PM.

[Conference_pear]

Hi ms Mars,

 

Yes, once a year the water of the watertank (5000 l) with transport water (continuous flow of fresh tapwater at 150 l  an hour) is sampled and sent for analysis. After every production run the water is changed, the tank cleaned and refilled.

 

We also work with different programs on residu's; residu-free, low-residu,... so on some days we change the water maybe 3 to 4 times.

[Scampi]

what part of the world are you in???

 

I wish IFSQN would remove the world option........it's hard to help when we don't know where you are lol

[Simon]

Ha ha some people prefer not to say. Either see themselves as citizens of the world or more likely they want to be incognito.

Sent from my SM-G950F using Tapatalk

[Conference_pear]

Scampi,

 

The temperature at reception applies to pre-cooled bulk fruit of pre-packed fruit. This can be a factor for us to reject a batch. 

 

If the freshly picked fruit enters the facility in bulk bins at high temperatures (about 25 °c at core) then we store them for 24 hours in seperate cold stores with super high ventilation and spaced more then 1 m apart in colums of 10 to 12 bins. After the 24 hours the temp. is re-assessed and if found fit they are moved to final storage.

 

Concerning the residu's... I performed a test with pears who were treated with boscalid, pyraclostrobine and tiophanate-methyl (as determined per analysis report). And after the test with chlorination the analysis report read boscalid, carbendazim (possibly the tiophanate that broke down) and chloorprofam (not allowed in fresh fruit) and the pyraclostrobin not detected (probably under limits or washed off)

[Conference_pear]

BTW I 'm from Belgium

[Conference_pear]

So I on one side I work for a fresh fruit packing company 3 days a week and 2 days for a IQF fruits trading company. This last one is a very exciting job, since I come in contact with so many fruit growing, producing and processing companies in the world. And since I also grow pears myself I can or try to relate to these other companies. Just a few minutes ago I was mailing about the cultivation of bananas in Ecuador... facinating!

[Scampi]

Bananas are a big deal right now.........i have heard the Cavendish variety almost got wiped out a year or so ago and almost every Banana sold is of that type

 

We process fresh asparagus........the owner will actually in Germany next month for international conference.............oh I wish I could go!

 

A lot of folks don't give produce processing enough weight....there are lots of things to consider that only exist in fresh/flash frozen

 

Ah, so the growers must be hydro cooling on farm prior to arrival at your facility...

 

I would still suggest you implement a water testing program within your facilities wall that occurs more frequently. I know CanadaGap requires at least 3, 1 pre season 1 during and 1 post to show that the water remained potable. So we test main line and a different location within the facility each month

[Conference_pear]

Thanks for the feedback! I really enjoyed your comments!

[Charles.C]

Hi koen,

 

Unless added in BRC8 (?), afaik BRC has absolutely zero interest in Control Points. Unlike SQF.

[Conference_pear]

Hi Charles,

 

Thanks for your post... so how should I call these points? Points of Attention? And is a summary of these points necessary?

[Conference_pear]

Bananas are a big deal right now.........i have heard the Cavendish variety almost got wiped out a year or so ago and almost every Banana sold is of that type

 

We process fresh asparagus........the owner will actually in Germany next month for international conference.............oh I wish I could go!

 

A lot of folks don't give produce processing enough weight....there are lots of things to consider that only exist in fresh/flash frozen

 

Ah, so the growers must be hydro cooling on farm prior to arrival at your facility...

 

I would still suggest you implement a water testing program within your facilities wall that occurs more frequently. I know CanadaGap requires at least 3, 1 pre season 1 during and 1 post to show that the water remained potable. So we test main line and a different location within the facility each month

Some growers pack themselves under the scope of global gap. They have their own facilities (cold stores and grading machine) and procedures.

 

Concerning hydrocooling; we only hydrocool the cherries. In 7 minutes we can bring their core temperature to 0 °C and at a capacity of 250 kg at a time. We have installed a buffertank with 10 000 l cooled water with coils running with glycol. Works very well to preserve the cherries up to 4 weeks with no degradation.

[Charles.C]

Hi Charles,

 

Thanks for your post... so how should I call these points? Points of Attention? And is a summary of these points necessary?

 

Hi koen,

 

Have you read the BRC7 Standard ? IIRC there is simply no mention of this aspect/requirement from the Standard's POV. Welcome to be corrected of course.

 

However what you prefer to do for yr own control purposes is IMO typically up to you.

 

Offhand, I can recall one thread here for BRC discussing the OP's use of Control Points. But I think this was due his/her parallel certification to SQF. A different situation perhaps.

[pHruit]

BRC is silent on naming convention for non-CCP controls beyond a general reference to "existing prerequisite programs", so does recognise their existence.

In one process flow we have a CP in addition to the CCPs and BRC auditors have never quibbled with this in 10 years of certification..

For the OP - see 2.7.3 in Issue 7 or 8. Assuming it works with your hazard analysis, I don't see why you couldn't call them CPs or reference the perquisite program that controls the risk/process.

I did include a summary table for the single CP in the relevant HACCP plan just because it could easily be summarised in that form and I wouldn't see a specific problem with doing this, as long as (a) the people actually doing the process can readily understand it and (b) it's clear to the auditor that it's not a CCP - if you draw too much attention to it there is perhaps a risk of them thinking it is more significant a hazard than it is and thus that it should be a CCP. Being audited is as much about perception of your site/systems as it is about the actual site/systems themselves

 

For your SOPs, again it's probably not too critical either way - any auditor for BRC should be familiar with the idea of an SOP, although the standard itself refers to Work Instructions (see e.g. 1.2.2, 3.1.3, 6.1 etc).

[Charles.C]

Hi pHruit,

 

I agree, it's up-to-you. Although, referencing the thread title, I would imagine BRC might be a little taken aback to find OPRPs on a (brc specified) Codex haccp system.

 

Just to note that Codex (the original haccp one ) only require CCPs to be identified although, from memory,  there is an implicit comment towards PRPs.

 

IMEX other than the above, one can simply generate a (very) large QA manual of "Procedures".

 

But not for SQF.

 

PS - the use of Prerequisites became instantly popular when it was realized that this auto-deleted the necessity for having multiple CCPs at the receiving material stage.

[Conference_pear]

Hi everyone,
 
Reviewing all comments I lost my confidence a little bit in the analysis I performed. I 've attached the file and hope for some feedback.
 
Regards,
 
Koen

 

 

Attached Files

•  4_Hazard work sheet.doc   151.5KB   103 downloads

[Scampi]

Are farmers packing grounders?

 

Are they all GlobalGap (or most anyway)?

Edited by Scampi, 18 October 2018 - 01:58 PM.

[Conference_pear]

What are grounders?

[Conference_pear]

I understand your question.

 

No they pack apples and pears. But during harvest there are so many things that can go wrong. The fruit is picked in wooden bins (there is a movement of changing to plastic, but slow). The quality of the bins is re-assessed yearly by the growers. But the bins, harvest equipment,... all is handled in the orchard. A worker can be trained in hygenic measures but a bin can always be contaminated from standing on the soil.

 

The trees are about 4 m high and the positioning of the fruit on the tree is from 0.2 m upto 4 m and yes some can hang on the ground.

[Conference_pear]

All Global Gap certified option 1 is a requirement for our co-operation. I 'm responsible for the guidance on that matter towards the growers.

[Scampi]

ok, i'm trying to understand how fecal matter from the ground would end up IN the bin (wood or otherwise) so how would the fruit then be contaminated...........and on farm training should ensure that dropped fruit stays dropped-----unless you've swabbed for ecoli and know that is has happened......I'm not saying it couldn't, but I would think in an orchard setting, the risk non existent (unless it's a personnel hygiene issue and not a harvesting practices issue)

 

 

Our fields are all harvested by hand as well, but they all have sanitize wipes with them for hands (if needed) and knives

 

All of these harvesting "hazards" should be controlled on farm under GLobalGap and therefore not hazards for you (with the exclusion of things like leaves and branches and flying pests)