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SQF Ed. 8 - 2.4.8, justifying an exclusion on Environmental Monitoring


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HokeyPokey

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Posted 07 May 2019 - 05:47 PM

I work in a meat plant and we do not have environmental program for our Raw Ground and Raw Not Ground plan.  Can we do a Risk Assessment on Why do we do not have a Environmental Program and meet the Code. 

 

Or 

 

Do we need to have a program and do some testing. 

 

Feedback is welcome. 



Amanda Cross

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Posted 07 May 2019 - 05:51 PM

Hello!  I am in the same position in a raw meat plant.  We test twice per month for SPC to validate the cleaning/pre-op programs and as an indicator for filth that could contaminate product.  I use the current USDA pathogem testing program as our pathogen element with trending and a CA plan in place if USDA testing ever reveals an issue.  It's not the strongest plan out there, but I have a very small plant and limited resources to test for a pathogen that I already expect to find in a raw plant.



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SQFconsultant

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Posted 07 May 2019 - 06:05 PM

You can write up a risk assesment as to why you do not do it - better have a substantial reason, otherwise prepare to be written up.


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Setanta

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Posted 07 May 2019 - 06:36 PM

Hello!  I am in the same position in a raw meat plant.  We test twice per month for SPC to validate the cleaning/pre-op programs and as an indicator for filth that could contaminate product.  I use the current USDA pathogem testing program as our pathogen element with trending and a CA plan in place if USDA testing ever reveals an issue.  It's not the strongest plan out there, but I have a very small plant and limited resources to test for a pathogen that I already expect to find in a raw plant.


You test twice per month in a raw meat facility? We test ATP 3 times a week and Listeria/Salmonella weekly and we just assemble precooked ingredients.

-Setanta         

 

 

 


The Food Scientist

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Posted 07 May 2019 - 06:53 PM

I work in a meat plant and we do not have environmental program for our Raw Ground and Raw Not Ground plan.  Can we do a Risk Assessment on Why do we do not have a Environmental Program and meet the Code. 

 

Or 

 

Do we need to have a program and do some testing. 

 

Feedback is welcome. 

 

I am failing to see why you wouldn't have one in the first place. Given you have a high risk product. and the amount of recalls we get due to contaminated meat. Especially your ground meat, there is a higher chance of contamination there from your surfaces and surroundings. In my opinion, you should do some testing not only for meeting the code, but for regulatory reasons.


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


Charles.C

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Posted 08 May 2019 - 01:19 AM

I work in a meat plant and we do not have environmental program for our Raw Ground and Raw Not Ground plan.  Can we do a Risk Assessment on Why do we do not have a Environmental Program and meet the Code. 

 

Or 

 

Do we need to have a program and do some testing. 

 

Feedback is welcome. 

 

Theoretically Yes/No.

 

But see this Scampi-driven thread (there are related Posts in other threads also), esp. Post 9.

 

https://www.ifsqn.co...toring-program/


Kind Regards,

 

Charles.C


3560lynne

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Posted 08 May 2019 - 05:09 PM

We do not test the environment in the processing area for raw meats based on prerequisite programs, supplier approval process requirements, separation of functions, gmps as a result we do not introduce a significant food safety hazard from the environment in the final product, it's not a USDA regulation.



The Food Scientist

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Posted 08 May 2019 - 05:12 PM

I would imagine not needed thinking about it, theres no kill step and it's not RTE. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


3560lynne

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Posted 08 May 2019 - 05:16 PM

Right, product is labeled with safe handling instructions (USDA requirement) consumer applies lethality step to product. Risk assessment complete. 



Marshenko

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Posted 08 May 2019 - 05:32 PM

Mhm, hold and test for E.coli stecs and salmonella on a regular basis (based on history), ATP swabs on product contact surfaces during pre-op.  Easy.

 

Right, product is labeled with safe handling instructions (USDA requirement) consumer applies lethality step to product. Risk assessment complete. 



Marshenko

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Posted 08 May 2019 - 05:33 PM

Raw meat in the US is not considered high risk.

 

I am failing to see why you wouldn't have one in the first place. Given you have a high risk product. and the amount of recalls we get due to contaminated meat. Especially your ground meat, there is a higher chance of contamination there from your surfaces and surroundings. In my opinion, you should do some testing not only for meeting the code, but for regulatory reasons.



Scampi

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Posted 10 May 2019 - 12:54 PM

hold the phone

 

Beef Pork or poultry?????


Please stop referring to me as Sir/sirs


Hoosiersmoker

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Posted 16 May 2019 - 01:47 PM

Make sure your risk assessment identifies all of the points from the above posts. You should swab 8 or 10 areas in your facility and include the results with your request (unless they show high levels of pathogens / bacteria). Clarify each in a written document as well as the other factors you feel contribute to your contention. Sent it to the technical dept of your CB and wait for their response. If they accept it, great! If not, they should send a response with the reason for denying the request, you might still get the exemption if you can adequately show their assessment is flawed and why, or it might have just been information you didn't include initially and re-submit that with the exemption request.

 

We are (still) in the process of requesting the same exemption. We produce paperboard packaging (for over 70 years) and, unfortunately, deterimned in house that the spirit as well as the letter of the code did not apply and we got a major NC as a result. The risk assessment information was contained within our HACCP plan but not separately on a matrix. We have, however, successfully received an exemption from Food Fraud. It is possible but make sure you do your homework.

 

Good Luck






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