We have recently had our initial FSSC audit, and passed with a few minors.
One of the minors is confusing me, I would like to hear your opinion on this:
Our raw materials are frozen slaughter byproducts which are obtained from EU approved slaughterhouses, most of them are IFS/BRC certified. We do not receive productspecifications from all of them, so in some cases we have them sign our own raw material specification. In this specification I have included "salmonella absent/25g" as specific microbiological criterium, also to the criterium that the raw material needs to be derived from animals that are slaughtered in EU approved slaughterhouse, and comply to the 853/2004, etc. etc. This specific specification is for turkey skins and in the 2073/2005 I can not find any other criterium for pathogens for these products.
In my risk analysis I have mentioned the theoretical possibility of presence of pathogens as salmonella, listeria, E. coli,. Staph. Aureus, etc. Since we have a very effective germ reducing process, presence of these are no high risk, (unless ofcourse there are such high numbers the toxine would be a risk, but there are other measurements to prevent that)
The auditor dit not accept the specification because it only mentioned the absence of salmonella and therefor it did not match the risk analysis.
When I look at the microbiological requirements for fresh meat (which is going to have a germ-reducing step) in the 853 or 2073 I can only find requirements for the absence of salmonella. She thinks I need to include also limits for the presence of other pathogens. But what limits do I need to include, I have examples of specifications for raw materials from other suppliers, but they are all different, also do not mention all pathogens and since there are no specific limits mentioned in legislation I have no clue what to include in the specification. It is not possible to require "absence of all pathogens" because of the material (frozen slaughter by products), and we do not monitor the microbiological quality of the incoming raw materials (I do ask for monitoring reports from our suppliers). She did not ask for any specification of other suppliers, so I do not know what her opinion was on those.
How should I solve this one...
Thank you in advance!