12 replies to this topic

[Muddy]

Hi there, 

 

Complete newbie to this and have been unsurprisingly thrown into the deep end by my company and I have no idea where to start.

 

We have had a consultant come in and has set up a new HACCP plan for us.  Within this plan are some new CCP's and prerequisites which, due to the inexperience of senior management, have never been seen as an issue before.  We are a fresh produce packer and all produce supplied by us is either washed or washed and cooked at the final stage before consumption by the final consumer i.e. whole Brussel sprouts, apples, pear etc. One of our processes involves ice made using mains water.  It is solely used to top fresh vegetables, which should be washed before consumption. 

 

Should we be environmentally testing the ice machine for listeria as has been suggested?  How do we do this? Should we test our packing surfaces for anything else? I have approached several places about this and they have been very unhelpful and start talking in scientific terms which I have no idea what they are talking about and the kit all seems expensive so can someone explain in layman terms what we should do.

 

[Scampi]

Ice machines can be VERY nasty machines for food borne pathogens and MUST be included on a sanitation schedule

 

http://www.inspectio...2/1528206588981

 

You should be:

 

Testing the main water line as well as various locations throughout your facility for potability

Testing ice from the ice maker for potability

 

Both of which should be done at a minimum of MONTHLY

 

You cannot factor in the cooking by the consumer as part of your process control..........alot of vegetables MAY be consumed raw (including Brussel sprouts)

 

Could you kindly share what CCP's the consultant issued?  It seems odd that a fresh produce pack house would have more than 1 (chlorine in the washwater)

[MrHillman]

Contact a swab provider. In our case Hygiena, they sent a consultant out to show us how to use their products. Like you, I was thrown into this fascinating field by my employer, together we are learning. That consultant said that we may do our own swabbing to ensure things are safe, but must still send samples to lab for verification.

[MsMars]

Contact a swab provider. In our case Hygiena, they sent a consultant out to show us how to use their products. Like you, I was thrown into this fascinating field by my employer, together we are learning. That consultant said that we may do our own swabbing to ensure things are safe, but must still send samples to lab for verification.

 

You could also contact your outside lab to see if they will do sampling training - many of them provide testing materials as well as part of your contract.  Some labs also provide consultation on environmental monitoring and sampling.  

[012117]

Hi, Muddy.

 

I am not so familiar with fresh produce but to aid you, some questions below may help. We do sample for listeria for the 1st plant I worked with, yes, it can be very expensive, but you can work your way through provided the proper risk assessment.

 

You just mentioned consultant help you defined CCP? is one include washing and is ice addition before or after washing? and from ice addition, how is it packed?

 

Also , on top of the cooking, while "most" knew it should be washed, if it not properly communicated (atleast on the label), then should not rely on this as much.

 

What I suggest is that:

 

1. Refer to questions above on how it may aid you in the risk.

2. Refer to your current control and design, how hygienic is your ice maker, have you seen what it look like? are there no traces of slime? What is the cleaning scheme for this and how frequent? This will aid you in your confidence. If it is not hygienic, sampling will just give you the obvious.

3. Your consultant also may help you in defining the sampling and frequency, if not so much knowledgeable on sampling technique or available method, you may request if consultant have contact or you outsource yourself and request your consultant to help you to understand in more layman term.

[Charles.C]

Hi Muddy,

 

I deduce you are likely unfamiliar with haccp ?

 

If so, you will surely need to get some technical training asap.

 

You are unlucky in that fresh produce is well-known to be a difficult product area with respect to developing haccp plans.

 

As I understand yr post, all yr (raw) finished product is labelled as requiring "cooking" by consumer. ie nothing is RTE. (seems strange ?)

 

This (fortunately)  theoretically usually places yr product in a Low Risk area from customer's Safety POV.

 

IMO the consultant who already provided yr haccp plan should be well-capable of answering queries like those discussed in this thread.

 

Regardless of ice, it is IMO quite likely that you will anyway detect Listeria in yr finished product. It is ubiquitous in the agricultural  environment.

 

Note that Listeria, per se, is not a pathogen. Unlike L.monocytogenes.

[cindyhaz]

Hi Muddy,

I, too, am in the fresh produce packing business.  Relying on the consumer to wash or cook the product doesn’t remove risk. FDA considers all produce that isn’t cooked to be a raw agricultural commodity that is high risk.

 

Test the ice machine frequently for Listeria ssp as an indicator of your cleaning efficiency. We conduct routine environmental testing for Listeria ssp by using an outside laboratory that provides us with coolers and swabs. It’s my understanding that FDA is going into produce companies and swabbing. I know of one facility (a tomato packinghouse) in which 120 swabs were taken to be tested for Listeria.  They went so far as to swab ceiling rafters, nonfood contact packing tables, and even the button on the coke machine.  FDA will require you to have a well thought out environmental testing program that details corrective actions. FDA has very specific requirements for testing Listeria, so be sure your lab follows accepted protocols.

 

Are you testing your water for coliforms? We have to test our water quarterly even though we use city water. Our lab has to be State certified to test drinking water.

 

Besides having a HACCP plan, we are required by FSMA to have a Food Safety Plan that requires a little more depth and utilizes some differences in terminology. I’m required to be certified as a Preventive Control Qualified Individual.

 

If you want to reach out, I’m happy to help you in any way I can. I strongly suggest you look into United Fresh Produce Association. Their training is specific to produce and they are in frequent contact with FDA with regard to rule making, but especially when an outbreak occurs. Their weekly emails are full of important information regarding produce safety. Last, you will want to become very familiar with the Produce Safety Rule and Food Safety Modernization Act. Regulatory expectations for the industry have changed dramatically in the last few years. United Fresh has helped us understand the requirements.

 

Cindy

[Charles.C]

 

Hi Muddy,

I, too, am in the fresh produce packing business.  Relying on the consumer to wash or cook the product doesn’t remove risk. FDA considers all produce that isn’t cooked to be a raw agricultural commodity that is high risk.

 

Test the ice machine frequently for Listeria ssp as an indicator of your cleaning efficiency. We conduct routine environmental testing for Listeria ssp by using an outside laboratory that provides us with coolers and swabs. It’s my understanding that FDA is going into produce companies and swabbing. I know of one facility (a tomato packinghouse) in which 120 swabs were taken to be tested for Listeria.  They went so far as to swab ceiling rafters, nonfood contact packing tables, and even the button on the coke machine.  FDA will require you to have a well thought out environmental testing program that details corrective actions. FDA has very specific requirements for testing Listeria, so be sure your lab follows accepted protocols.

 

Are you testing your water for coliforms? We have to test our water quarterly even though we use city water. Our lab has to be State certified to test drinking water.

 

Besides having a HACCP plan, we are required by FSMA to have a Food Safety Plan that requires a little more depth and utilizes some differences in terminology. I’m required to be certified as a Preventive Control Qualified Individual.

 

If you want to reach out, I’m happy to help you in any way I can. I strongly suggest you look into United Fresh Produce Association. Their training is specific to produce and they are in frequent contact with FDA with regard to rule making, but especially when an outbreak occurs. Their weekly emails are full of important information regarding produce safety. Last, you will want to become very familiar with the Produce Safety Rule and Food Safety Modernization Act. Regulatory expectations for the industry have changed dramatically in the last few years. United Fresh has helped us understand the requirements.

 

Cindy

 

 

Hi Cindy,

 

Actually UFPA seem to strongly disagree with Fresh Produce being classified as High Risk. I attach 2 related documents below.

 

Their White paper certainly contains useful microbiological information but, IMO, the section (see pg 10 et seq) on Environmental Testing includes some distinctly questionable microbiological statements. No specific  validatory references are given. It is also unclear (to me) whether the paper is referring to RTE, NRTE, or both.

 

I do believe it is true that RTE Fresh Produce is currently  in the top 10 of (unofficially?) high risk classified foods in USA but I suspect this may be related to "recent"  events involving  pathogenic E.coli rather than  L.monocytogenes. Risk from pathogenic E.coli is discounted in the White paper.

 

 White Paper - micro.testing fresh produce.pdf   127.88KB   70 downloads

 Designation-of-High-Risk-Foods.pdf   396.01KB   63 downloads

[cindyhaz]

Hi Charles,

Thanks for the input. I agree that UFPA would likely prefer that fresh produce is not classified as high risk (as I would!), but I believe that’s FDA’s perspective. There have been significant outbreaks and resulting changes in the regulatory environment since UFPA published this white paper in 2010. UFPA hasn’t updated this document, though it’s due. They still look for more science and validated micro. From my viewpoint they’ve been very focused on assisting FDA when there are outbreaks and educating their members about Listeria, FSMA, the Produce Safety Rule, and Foreign Supplier Verification Program. All of these things are relatively new demands on the produce industry.  

 

You might find this document on Industry Perspective on Environmental Monitoring for Listeria interesting.

 

Best,

Cindy

 

[Charles.C]

Hi Charles,

Thanks for the input. I agree that UFPA would likely prefer that fresh produce is not classified as high risk (as I would!), but I believe that’s FDA’s perspective. There have been significant outbreaks and resulting changes in the regulatory environment since UFPA published this white paper in 2010. UFPA hasn’t updated this document, though it’s due. They still look for more science and validated micro. From my viewpoint they’ve been very focused on assisting FDA when there are outbreaks and educating their members about Listeria, FSMA, the Produce Safety Rule, and Foreign Supplier Verification Program. All of these things are relatively new demands on the produce industry.  

 

You might find this document on Industry Perspective on Environmental Monitoring for Listeria interesting.

 

Best,

Cindy

 

Hi Cindy,

 

I didn't want to complicate the topic but another key factor is that one must define the criteria for high/low risk.

 

For example, if one adopts a purely Process  Haccp POV as the criterion, a raw item which is labelled to be cooked (by a validated method) by the consumer surely must be (micro)  low risk assuming that you are willing to trust the consumer. It's as simple as that.

 

However there are many, many other criteria in use also. As in the White paper.

FSMA proposed to issue a list based on a  multifactor "quantity" which they have now been trying to finalise for 4 Years.

 

PS - it's also a reality that USA are probably more "concerned"  about Listeria/L.mono than anywhere else in the World. Due historical reasons.

 

PPS - yr attachment got lost somewhere.

[Muddy]

Thanks for all the replies guys.  I am UK based, probably should have said so in the beginning  , but this is a great help.  We are a good bunch of people here but we are mostly from outside fresh produce.  I am more than capable of understanding audits and interpreting them, I just think people here see them as a boring chore as previous employees have tried to fit the business to the standard rather than ensuring what we are doing is to the standard therefore we have lots of unnecessary paperwork etc to streamline and make work for us.  

 

You have all been very helpful in pinning down some specific things we should be testing for.  I regularly read these forums for advice.  Thankyou.

[trubertq]

Remember the recalls from the supermarkets regarding frozen vegetables.... those were not RTE but people don't always do what processors expect them to do. Famous example , cookie dough in US that caused a salmonella outbreak because ppl ate it raw.

 

This is actually addressed in HACCP in step 3 of the preliminary steps to enable hazard analysis: Identify Intended use and any known alternative use.

 

https://www.fsai.ie/...frozen_veg.html

[Charles.C]

Thanks for all the replies guys.  I am UK based, probably should have said so in the beginning  , but this is a great help.  We are a good bunch of people here but we are mostly from outside fresh produce.  I am more than capable of understanding audits and interpreting them, I just think people here see them as a boring chore as previous employees have tried to fit the business to the standard rather than ensuring what we are doing is to the standard therefore we have lots of unnecessary paperwork etc to streamline and make work for us.  

 

You have all been very helpful in pinning down some specific things we should be testing for.  I regularly read these forums for advice.  Thankyou.

 

 

Hi Muddy,

 

Yes, it was a pity.

 

Now we need to have a another thread/discussion on control -  Listeria (UK) versus Listeria (USA). Etc, etc.

 

And perhaps whether a specific FS Standard is involved also ?

 

And why you apparently cook Apples and Pears ?