We are currently benchmarking FSSC22000:2005, we are not yet certified, but are exceedingly close.
I am working on the details of our bottling process and have arrived at the capping procedures.
We currently use a clean beer jug to get the lids out of the lid box. They are poured into a clean bowl where the employees take them, one by one, out of the bowl to cap the bottle/jar. When they finish capping the batch, the lids are returned to the box with the rest of the caps.
The employees can wear gloves or not, depending on which way is less physically destructive to them, but because we hand fill, the gloves or hands can touch the product during capping, and thus potentially create a raw material contamination to the caps that get returned to the box.
We heat process everything, so the food risk to the finished product is mitigated by that SOP.
Via the decision tree, we have determined that this is not a CCP because the risk to food safety is mitigated by the later SOP. Even so, it's a concern in that we're all trying to figure out how to flag so that it is clear that we are controlling the situation, and would prefer to have a best efforts resolution to the idea that a possibly contaminated cap is returned to the box.
We considered sterilizing them, but that adds moisture to the caps and then creates a new risk.
Has anyone else dealt with this issue, that can offer some ideas to write this into the PRP or how you dealt with this, please?
Appreciate all thoughts.
Hi Pepperfire,
So for starters, I'm not sure exactly what you are manufacturing. However, if you do use the same type of beer jug for your actual product, you could be risking a non-conformance. All containers you use for your product can only be used for their intended purpose. We used to have employees that would take jars and use them as pen holders and things like that. Our auditors would dock us for it, and I became a hound for looking for items where people were using our packaging "creatively". You could easily buy metal detectable scoops for the purpose of scooping lids from the lid boxes.
Given the repetitive movement and constant handling during capping, I would suggest gloves always for this. Yes, I know people abuse gloves and GMPs, but if done the right way, this is actually preferrable. Without gloves, you're risking your employees having cuts on their hands and twisting those caps on the bottles. Not to mention touching a bunch of caps, then dumping them back into the main cap area, and re-touching them again the next day. I'd probably suggest that you throw away the unused caps that were in the box the employees handled at the end of the day. Obviously this will be an additional expense, but reduces sanitation hazards. It sounds like you're a small operation, but you should really consider some automated capping, not just from a food safety perspective but from a safety perspective. Depending on how many bottles come down the line per day, you could be looking at some wrist and hand injuries. Also, how are you sealing your bottles?
When you talk about product going through a heating process, is the product heated after it's bottled and capped? This hazard is only mitigated if you are following proper time/temperature heating of product and have validated that the heating reduces/eliminates hazards. If it's heated before being bottled and capped, you haven't mitigated the risk of employees handling lids.
On the other hand, I don't think I would be considering the capping to be a CCP unless you were working with a high risk beverage or food; like a low-acid food that goes through a scheduled process (and the processing authority deemed you to do some kind of process at the time of capping). However, you do need to be watching the handling process of these lids.