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#1 Carol88

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Posted 17 April 2019 - 10:59 PM

Hi, looking for info and help.

We process & pack whole citrus fruit & avocados. Fruit comes from orchards to us where they undergo drenchers, fungicide washes , rinses, sanitation washes, waxes and packed into outer packaging and on sold to supermarkets & other markets. I don't want to go down the path of listeria and e-Coli testing of the conveyor belts and throughout the factory if possible. Could I get away with just a risk assessment

Cheers Carol  



#2 Ryan M.

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Posted 17 April 2019 - 11:04 PM

Depends....on what regulations and or certification standards in which you need to comply.

 

Almost always...you will need some kind of environmental monitoring program.  If you are hesitant to test / swab the facility and environment it tells me you know there are problems.  Fastest way to fix those problems is systematically find them and attack them.

 

Do you really want to risk your customer(s) and in turn risk your business?  



#3 Carol88

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Posted 17 April 2019 - 11:15 PM

Depends....on what regulations and or certification standards in which you need to comply.

 

Almost always...you will need some kind of environmental monitoring program.  If you are hesitant to test / swab the facility and environment it tells me you know there are problems.  Fastest way to fix those problems is systematically find them and attack them.

 

Do you really want to risk your customer(s) and in turn risk your business?  

Hi Ryan we are under SQF and there are no problems that we are aware of. We have a strong factory cleaning program but I suppose I am wondering if once the fruit goes through its treatment process then shouldn't it be protected against pathogens.



#4 Ryan M.

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Posted 18 April 2019 - 05:33 AM

Hi Ryan we are under SQF and there are no problems that we are aware of. We have a strong factory cleaning program but I suppose I am wondering if once the fruit goes through its treatment process then shouldn't it be protected against pathogens.

 

I would say unless you have....

 

1.  Very strong traffic control programs

2.  Very strong GMP's and personnel practices

3.  Very strong water control program

4.  Very strong sanitation and sanitation monitoring activities (micro testing, ATP swab testing, etc.)

 

You should have an environmental monitoring program for pathogens of risk, e.coli and listeria.  

 

My first question, if I was your auditor, is "What is your traffic control program like?  Does it prohibit personnel from moving across areas / zone?"  The follow-up question would be "What monitoring programs do you have in place for sanitation and water?"

 

The biggest concern I see is tracking the pathogen from one area to another.  But if you have strong programs, and you are monitoring your sanitation through indicator microorganisms before / after sanitation then you can possibly show a pathogen monitoring program is unnecessary.

 

However, I personally wouldn't try that.  I'd do the environmental pathogen monitoring.  As stringent as your cleaning process is you may find something eye opening.  In several facilities I've been in the one area that is a hot spot, yet doesn't get much concern is the trash / waste area.  In a lot of plants many personnel have access to this area and foot traffic goes back to various areas in the facility.



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#5 zanorias

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Posted 18 April 2019 - 05:42 AM

Hi Ryan we are under SQF and there are no problems that we are aware of. We have a strong factory cleaning program but I suppose I am wondering if once the fruit goes through its treatment process then shouldn't it be protected against pathogens.

 

Hi Carol,

 

Regardless of whether the treatment should protect against pathogens, we need to be confident that it does, especially if you're handling product before packing. Pathogens in my cooked meat products should be reduced to a safe level in the cooking but I can't assume that is the case, or that the equipment and surfaces around the food prior to packing are sufficiently clean. They should be, but we test them to find out hence environmental swabbing of the zones and product sampling. I'm unfamiliar with SQF or US requirements but I'd imagine you'd struggle with due diligence if you didn't have an environmental programme or at least some kind of validation that the hygiene levels are sufficient.

 

If your factory cleaning process and relevant procedures are strong and implemented fully then you shouldn't have an issue. However best  to test it and be sure, and if there is and issue you can address it appropriately. Have you already done your risk assessment?



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#6 Carol88

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Posted 18 April 2019 - 05:54 AM

Hi Carol,

 

Regardless of whether the treatment should protect against pathogens, we need to be confident that it does, especially if you're handling product before packing. Pathogens in my cooked meat products should be reduced to a safe level in the cooking but I can't assume that is the case, or that the equipment and surfaces around the food prior to packing are sufficiently clean. They should be, but we test them to find out hence environmental swabbing of the zones and product sampling. I'm unfamiliar with SQF or US requirements but I'd imagine you'd struggle with due diligence if you didn't have an environmental programme or at least some kind of validation that the hygiene levels are sufficient.

 

If your factory cleaning process and relevant procedures are strong and implemented fully then you shouldn't have an issue. However best  to test it and be sure, and if there is and issue you can address it appropriately. Have you already done your risk assessment?

Hi Zanorias I have completed a risk assessment. all the fruit is pre-washed and sanitized before entry to factory and then all fruit goes through several sanitizing treatment processes with the final process being a wax and then onto conveyor belts for sizing and packing. all staff that sort or touch fruit wear cotton gloves. the sanitizing treatment says that it eliminates the pathogens.  



#7 zanorias

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Posted 18 April 2019 - 06:07 AM

What does the SQF require on this? 

 

My concern would be contamination between sanitation and packing i.e. if the belt isn't cleaned sufficiently.



#8 pHruit

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Posted 18 April 2019 - 08:56 AM

These links may be of assistance:

https://www.ifsqn.co...rus-pack-house/

https://producesafet...1015_screen.pdf

https://fpsc-anz.com...67-dec-2002.pdf

 

The IFSQN thread in particular links through to some other threads with many further links. Quite a lot of reading, so hopefully more information is better than less.

 

Hi Zanorias I have completed a risk assessment. all the fruit is pre-washed and sanitized before entry to factory and then all fruit goes through several sanitizing treatment processes with the final process being a wax and then onto conveyor belts for sizing and packing. all staff that sort or touch fruit wear cotton gloves. the sanitizing treatment says that it eliminates the pathogens.  

 

If you're using a sanitizer then it probably won't achieve complete sterility (otherwise it would be a sterilizing treatment ;) ), and the actual efficacy of the kill will depend on various factors such as concentration, incoming contamination level, etc etc.

This isn't necessarily a problem as you're packing fresh fruit, and even as we edge further towards a world where we apparently expect even raw meat to be completely safe to eat without further processing, it is still broadly (thankfully) accepted that fresh fruit is not sterile.

Nonetheless I'd be looking at a risk-based targeted program for EMP - some areas of your plant will almost certainly show contamination, as the incoming fruit will have bacteria on it. What you're therefore perhaps trying to monitor and understand is if/how this progresses through your factory. As Ryan M noted, staff inadvertently acting as the vector to transfer from one area to another is perhaps your focus, as you know there is a high probability of introduction via raw materials.

Personally I'd start a sampling program, as there are theoretically only two outcomes to this, either of which would be helpful for you:

1) If you start sampling and find that your existing hygiene programs are effective then you can always use this as a basis to review the risk assessment and reduce sampling frequencies. This has cost you a small amount of time/money, but provided further data to support your existing system.

2) If you find there is a problem, then you've found it early before it potentially creates a much larger issue. It may not seem like it at the time, but catching it before it's too late really is a positive outcome.



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#9 zanorias

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Posted 18 April 2019 - 09:27 AM

 

2) If you find there is a problem, then you've found it early before it potentially creates a much larger issue. It may not seem like it at the time, but catching it before it's too late really is a positive outcome.

 

This can never be emphasised enough! 



#10 Charles.C

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Posted 18 April 2019 - 10:52 AM

IIRC Scampi has posted here a few times (for SQF) relating to S's request for nil EMP monitoring based on S's risk assessment evidencing a result of Low Risk.

 

iIRC the conversation with SQF was/is still ongoing, ie not accepted yet. :smile:

 

However, offhand, I anyway doubt that the Product/Process of this thread would be regarded by SQF as "Low Risk" ?


Kind Regards,

 

Charles.C


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#11 tsebring

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Posted 18 April 2019 - 12:42 PM

We fresh-pack citrus and have an on-going environmental monitoring program in place.  While the idea of getting a positive result can be stressful, a program will help you adjust your cleaning efforts and other processes, and prevent something worse from happening.  Here are a couple of comments that might help you as you take on a program:

 

1.) Define what to test for, what is acceptable as a result (which may depend upon what you found, where you found it, etc).  For citrus, the three pathogens most likely to cause issues are Listeria, Salmonella, and E-Coli.  I don't know avocados. but I'm sure you can locate some research on them.  

 

2.) Time your testing after cleaning, but then always have your team reclean those areas immediately after taking the tests.  This gives you a clean break.  Make sure that is documented in case you get a positive result.  

 

3.) Because our log reductions occur early in the process, I focus our testing on the later part of the line/processes.  Not exclusively by any means, but a majority of tests are in areas after those reductions have occurred.  Those nice big log reductions mean nothing if there are bad little bugs hanging out afterwards waiting for a ride.  Assume your line is similar.

 

4.) Focus on food contact surfaces, but also check your outer zones - floors, drains, under your A/C units, etc.  A lot of issues that people have had seem to have occurred when something worked its way from outer zones inward.

 

If you are using the same line for both citrus and avocados, I would think that your risk assessment would be higher than if just one crop.  And while citrus (not juice or juicing) has not been implicated in a recall to date (that I can locate or that anyone that we interact with is aware of), the same cannot be said of avocados.  And even in citrus, it's been scientifically proven that pathogens on the peel can be transferred to the fruit when being peeled.

 

If you are really worried about what you might find, and don't have to start immediately for a GFSI scheme, if you have a down season (aka summer), do some testing then.  That would give you a chance to react to any negative results without worrying about the cost of a recall.  Not really the ideal approach, but it would give you some time to get comfortable and clean up any issues if you find them.  That way when you go into a new season, you are ready and have strengthened your verification processes.  

 

Finally, not related, but here's a good recent article about the effectiveness of different citrus packing house processes and their related log reductions that you might be useful.  Comes out of Florida Citrus Research Center (Univ. of Florida): https://doi.org/10.1...fm.2018.10.014 

 

IMO, it's better to find an issue yourself, then get a phone call from a regulatory official....

 

Good luck...



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#12 KarrieC

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Posted 18 April 2019 - 03:08 PM

Newby here.  We pack dry non ready to eat pasta.  I'm hoping that makes us low risk but it was suggested at our last audit we start an enviromental monitoring program.  We do not have an onsite lab.  Very small company.  Myself and 1 assisant (in training).  Is there a way for me to do this in house?  Or would I need to send samples to an outside testing facility?  I imagine I would be testing the garbage area, bathrooms, cafetierias as well as any food surface- belts, tables,etc in the production area.



#13 Agrumeambu

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Posted 18 April 2019 - 03:22 PM

Hi Karrie !

 

I thought we were low risk and didn't have to do any environnemental testing. We did a risk assessment which didn't work with our auditor and landed us a minor. I do a ATP swab on walls / ceilings / drains / sinks at least once a month in different areas. All you need for those is an incubator and the appropriate Swabs / meter. I have to swab, then incubate for 7hours then I can read them. It shows me the amount of bacteria that could be there. Since E.Coli, Salmonella and Lysteria aren't a concern for our sector, SQF approved that type of testing last year. 

 

Just a risk assessment won't be enough I believe, they will still want you to check the environnement of your product. I can send you the equipment we use for the swabbing and such, I just didn't know if it was appropriate to do so on the forums :)

 

As for Carol, even if you believe you are low risk (like we did), a risk assessment won't be enough for them. You can always try, but I am pretty sure they will give you a non-compliance and have you build that program. 

 

Have a good day ! :)



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#14 Charles.C

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Posted 18 April 2019 - 04:47 PM

Hi Karrie !

 

I thought we were low risk and didn't have to do any environnemental testing. We did a risk assessment which didn't work with our auditor and landed us a minor. I do a ATP swab on walls / ceilings / drains / sinks at least once a month in different areas. All you need for those is an incubator and the appropriate Swabs / meter. I have to swab, then incubate for 7hours then I can read them. It shows me the amount of bacteria that could be there. Since E.Coli, Salmonella and Lysteria aren't a concern for our sector, SQF approved that type of testing last year. 

 

Just a risk assessment won't be enough I believe, they will still want you to check the environnement of your product. I can send you the equipment we use for the swabbing and such, I just didn't know if it was appropriate to do so on the forums :)

 

As for Carol, even if you believe you are low risk (like we did), a risk assessment won't be enough for them. You can always try, but I am pretty sure they will give you a non-compliance and have you build that program. 

 

Have a good day ! :)

 

There seems to be some confusion.

 

ATP measurements have no quantitative relationship to pathogens. And similarly to bacterial levels unless validated.


Kind Regards,

 

Charles.C


#15 Charles.C

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Posted 18 April 2019 - 04:58 PM

Newby here.  We pack dry non ready to eat pasta.

  I'm hoping that makes us low risk but it was suggested at our last audit we start an enviromental monitoring program. 

We do not have an onsite lab.

  Very small company.  Myself and 1 assisant (in training).

  Is there a way for me to do this in house?  Not without some equipment. It may also be blocked by local Regulatory issues.

Or would I need to send samples to an outside testing facility? Yes if you have no equipment.

I imagine I would be testing the garbage area, bathrooms, cafetierias as well as any food surface- belts, tables,etc in the production area..Need risk assessment, eg zoning analysis.

 

 

Assuming this is SQF. I suggest you read the relevant clauses in the Standard/Guidance.


Kind Regards,

 

Charles.C


#16 MsMars

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Posted 18 April 2019 - 08:41 PM

Newby here.  We pack dry non ready to eat pasta.  I'm hoping that makes us low risk but it was suggested at our last audit we start an enviromental monitoring program.  We do not have an onsite lab.  Very small company.  Myself and 1 assisant (in training).  Is there a way for me to do this in house?  Or would I need to send samples to an outside testing facility?  I imagine I would be testing the garbage area, bathrooms, cafetierias as well as any food surface- belts, tables,etc in the production area.

 

Hi Karrie, 

Setting up an in-house laboratory can get expensive for a small facility.  It's probably going to be much cheaper for you to send your samples to an outside laboratory. 

 

As far as your risk level, you will have to perform a risk analysis similar to what's described above.  IMO dried pasta isn't quite "low risk", as you have some of the same issues as flour, dough, etc. i.e. the risk of consumers ingesting raw/undercooked product. Eating raw pasta sounds silly, but one example: did you ever make dried pasta crafts/necklaces as a small child? Likelihood of kids chewing on raw pasta: you do the math.



#17 Charles.C

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Posted 19 April 2019 - 03:26 AM

We fresh-pack citrus and have an on-going environmental monitoring program in place.  While the idea of getting a positive result can be stressful, a program will help you adjust your cleaning efforts and other processes, and prevent something worse from happening.  Here are a couple of comments that might help you as you take on a program:

 

1.) Define what to test for, what is acceptable as a result (which may depend upon what you found, where you found it, etc).  For citrus, the three pathogens most likely to cause issues are Listeria, Salmonella, and E-Coli.  I don't know avocados. but I'm sure you can locate some research on them.  

 

2.) Time your testing after cleaning, but then always have your team reclean those areas immediately after taking the tests.  This gives you a clean break.  Make sure that is documented in case you get a positive result.  

 

3.) Because our log reductions occur early in the process, I focus our testing on the later part of the line/processes.  Not exclusively by any means, but a majority of tests are in areas after those reductions have occurred.  Those nice big log reductions mean nothing if there are bad little bugs hanging out afterwards waiting for a ride.  Assume your line is similar.

 

4.) Focus on food contact surfaces, but also check your outer zones - floors, drains, under your A/C units, etc.  A lot of issues that people have had seem to have occurred when something worked its way from outer zones inward.

 

If you are using the same line for both citrus and avocados, I would think that your risk assessment would be higher than if just one crop.  And while citrus (not juice or juicing) has not been implicated in a recall to date (that I can locate or that anyone that we interact with is aware of), the same cannot be said of avocados.  And even in citrus, it's been scientifically proven that pathogens on the peel can be transferred to the fruit when being peeled.

 

If you are really worried about what you might find, and don't have to start immediately for a GFSI scheme, if you have a down season (aka summer), do some testing then.  That would give you a chance to react to any negative results without worrying about the cost of a recall.  Not really the ideal approach, but it would give you some time to get comfortable and clean up any issues if you find them.  That way when you go into a new season, you are ready and have strengthened your verification processes.  

 

Finally, not related, but here's a good recent article about the effectiveness of different citrus packing house processes and their related log reductions that you might be useful.  Comes out of Florida Citrus Research Center (Univ. of Florida): https://doi.org/10.1...fm.2018.10.014 

 

IMO, it's better to find an issue yourself, then get a phone call from a regulatory official....

 

Good luck...

 

Hi tsebring,

 

Many thks for yr detailed input.

 

Unfortunately yr link seems to require $$$ other than the abstract.

 

I guess the link relates to the project described here although data does not fully cross-match -

https://iafp.confex....Paper15410.html

 

The specific process appears a mixture (maybe typical in the industry) of various chemicals/procedures  and apparently at pilot scale level.

The large range of reductions mentioned is clearly also relevant compared  to the max 2Log commonly quoted for fresh produce.

 

I noticed that (historically) the waxing stage may also be  "Xlog-significant", eg -

https://onlinelibrar....1999.tb15900.x

 

Certainly interesting to know what one may be consuming !

 

The links in Post 8 above eventually cover a lot of the basic fresh produce threads/knowledge on this Forum however, just as one example, I found the EMP-Listeria section in attachment below (bit old [2010] but presumably quite authoritative) interesting albeit rather "challenging" in respect to some of its sampling and micro. suggestions.

 

Attached File  White Paper- Microbiological Testing of Fresh Produce.pdf   127.88KB   24 downloads

 

PS - This is not my area at all but  if "avocados" includes melons, IIRC  the pH-micro. aspect gets rather more significant.


Kind Regards,

 

Charles.C


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#18 Agrumeambu

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Posted 19 April 2019 - 10:59 AM

There seems to be some confusion.

 

ATP measurements have no quantitative relationship to pathogens. And similarly to bacterial levels unless validated.

 

I may of called it wrong, English is my second language... I apologize.

 

I called it swabs because it is the same equipment that we use for our ATP testing, but different swabs. The ones for the environmental testing are two steps, one that has to incubate for 7 hours and the other one to use afterwards for the reading. This is a rapid bioluminogenic test method for the detection and enumeration of total population of bacteria or total contamination in a sample (down to 1 CFU) providing results in less than 8 hours. I copied this from their website so it would be a bit more clear what I meant :)

 

Sorry again and thank you !



#19 tsebring

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Posted 19 April 2019 - 12:00 PM

Hi tsebring,

 

Many thks for yr detailed input.

 

Unfortunately yr link seems to require $$$ other than the abstract.

 

I guess the link relates to the project described here although data does not fully cross-match -

https://iafp.confex....Paper15410.html

 

The specific process appears a mixture (maybe typical in the industry) of various chemicals/procedures  and apparently at pilot scale level.

The large range of reductions mentioned is clearly also relevant compared  to the max 2Log commonly quoted for fresh produce.

 

I noticed that (historically) the waxing stage may also be  "Xlog-significant", eg -

https://onlinelibrar....1999.tb15900.x

 

Certainly interesting to know what one may be consuming !

 

The links in Post 8 above eventually cover a lot of the basic fresh produce threads/knowledge on this Forum however, just as one example, I found the EMP-Listeria section in attachment below (bit old [2010] but presumably quite authoritative) interesting albeit rather "challenging" in respect to some of its sampling and micro. suggestions.

 

attachicon.gif White Paper- Microbiological Testing of Fresh Produce.pdf

 

PS - This is not my area at all but  if "avocados" includes melons, IIRC  the pH-micro. aspect gets rather more significant.

 

Sorry about that.  I got the paper originally from one of the authors, so I guess its ok to share here.  Their research was paid for by U.S. taxpayers after all.  

 

Attached File  Reduction of Escherichia coli, as a surrogate for Salmonella spp., on the surface of grapefruit.pdf   344.92KB   11 downloads



#20 zanorias

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Posted 19 April 2019 - 01:43 PM

I may of called it wrong, English is my second language... I apologize.

I called it swabs because it is the same equipment that we use for our ATP testing, but different swabs. The ones for the environmental testing are two steps, one that has to incubate for 7 hours and the other one to use afterwards for the reading. This is a rapid bioluminogenic test method for the detection and enumeration of total population of bacteria or total contamination in a sample (down to 1 CFU) providing results in less than 8 hours. I copied this from their website so it would be a bit more clear what I meant :)

Sorry again and thank you !


Hi Agrumeambu,

Out of curiousity do you have a link for the website? 7 hour incubation for pathogen enumeration seems very optimistic.

ATP itself is not exclusive to bacteria. This seems to be a common misconception and I've had many conversations with production staff trying to explain that they can't just "kill" ATP with sanitiser as a re-cleaning process following a high reading.

#21 Agrumeambu

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Posted 19 April 2019 - 02:19 PM

Hi Agrumeambu,

Out of curiousity do you have a link for the website? 7 hour incubation for pathogen enumeration seems very optimistic.

ATP itself is not exclusive to bacteria. This seems to be a common misconception and I've had many conversations with production staff trying to explain that they can't just "kill" ATP with sanitiser as a re-cleaning process following a high reading.

 

Good morning,

 

I do ! There it is : https://www.scigiene.../MicroSnapTotal

 

Whenever we have a high ATP reading from our preoperational inspection, they redo a cleaning for that non-compliant equipment until the reading is compliant. But for environmental, whenever it is non-compliant, since it is not in contact with food surfaces, they are recleaned at night then another test is taken in the morning.

 

If there is anything else, let me know !

 

Best regards,

Julie



#22 Charles.C

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Posted 19 April 2019 - 10:38 PM

I may of called it wrong, English is my second language... I apologize.

 

I called it swabs because it is the same equipment that we use for our ATP testing, but different swabs. The ones for the environmental testing are two steps, one that has to incubate for 7 hours and the other one to use afterwards for the reading. This is a rapid bioluminogenic test method for the detection and enumeration of total population of bacteria or total contamination in a sample (down to 1 CFU) providing results in less than 8 hours. I copied this from their website so it would be a bit more clear what I meant :)

 

Sorry again and thank you !

 

Hi Agrumeambu/Julie,

 

Thks for clarification.

 

The combined device (enrichment + ATP reading) for TVC has been previously noted here  -

 

https://www.ifsqn.co...bs/#entry125031

 

The (novel) procedure claims, as I understand it, to enable nullification of interference from non-microbial food debris.

 

Some more details here -

 

https://www.foodsafe...cator-bacteria/

Attached File  MicroSnap-Total.pdf   502.19KB   13 downloads

Attached File  MS Total, AOAC Certification.pdf   373.95KB   10 downloads

 

@zanorias - this unit/technique is specific for APC/TVC.  I agree with you that the enrichment media must be something special if it can change 48 hours to 7 and, seemingly, yield an equivalent growth profile. I deduced from the AOAC document that there may also be some mathematical juggling at the end...

 

Comments

 

the system is presumably intended to give a result similar to a standard (agar) plate count incubated at 30degC. This is atypical for some(many?) users.

The 2nd attachment above seems to only validate  product samples, not surface swabs. Maybe there are more documents available.

 

From a quick IT look, there do not seem many literature articles on practical evaluation of Microsnap  as yet. I noticed -

The MicroSnap Total method relies on the measurement of ATP as the prime metric. MicroSnap Total has not been evaluated with all possible products. See User Responsibility.

 

Regardless, if it performs as per specifications, the time is clearly appealing !. Cost no idea.


Kind Regards,

 

Charles.C


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#23 MBS713

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Posted 22 April 2019 - 07:13 PM

All,

our SQF auditor has asked for a risk assessment in order to determine the right locations are being tested. Have any of you been asked for this?



#24 Charles.C

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Posted 23 April 2019 - 05:06 AM

All,

our SQF auditor has asked for a risk assessment in order to determine the right locations are being tested. Have any of you been asked for this?

 

Seems to me that a risk assessment is implicitly included in the "zoning" ?


Kind Regards,

 

Charles.C


#25 tsebring

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Posted 23 April 2019 - 12:53 PM

If there has been any science done on your processes, you can rely on that as justification.  Another resource or methodology would be to see if your product/type has had recalls and if so, dig into the why and how and use that as well.  Otherwise, I just look at your HACCP analysis and zoning logic (as Charles mentions above) to determine the more "critical" spots.  (For example, if you have a kill step, then you would want to test after that to verify that you are not re-contaminating the product, etc).  I wouldn't overthink it too much.

 

Regardless of how, document your sources and logic.  Now you've framed the conversation for any audits.  Remember to make sure that your testing spots now align with your new logic. 

 

Personally, I was lazy (I mean efficient) and put my (rather simple) justification logic and the spots to test on the reverse side of my monitoring log itself.  We're seasonal, so I can justify not creating a new location logic each year.

 

Good luck....

 

Todd  



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