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Pepperfire

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Posted 09 August 2019 - 06:57 PM

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.



QAGB

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Posted 09 August 2019 - 07:25 PM

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. 



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Pepperfire

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Posted 09 August 2019 - 08:24 PM

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. 

We are a 1200 sq ft. hand batch facility. We do have nationally distributing clients, but we specialize in sometimes as few as a few dozen bottles per batch. One of our products includes hand stuffing garlic scapes into jars. Many of the client products are just not suitable to machine capping. It's one of the reasons why we decided to go with FSSC for our standard so we could be sure to mitigate any and all risks.

We have been doing this hand capping for over 40 years, and so far, the physical risk with this process is blisters. We have as yet not had anyone cut themselves to bleed during the bottling process, EXCEPT once when using an automated capper, and that came as a direct result of a defective bottle that had the neck snap off and the hand holding the bottle got cut. The SOP for using the automated capper isn't my issue, here.

We are doing a large variety of processed products, specifically targeting small batch customers, so it is imperative that we have PRPs that suit all situations, but I can never make all situations fit an automated capper, it won't happen, some packages require hand capping. The goal of our business is to ensure that handmade products can remain in business. Big Food has a bad habit of mainstreaming everyone into a million bottle filling line. THAT isn't our market. Some little old ladies want to keep selling their hand-picked wild strawberry jam safely, and we are their only support. So our goal is to maintain the small hand capping standard. In order to do that.

CNESST determined that the gloves are a worse if not the same physical hazard to the employee than the not wearing of them, short of a breakage incident happening, and as I said, the only time that ever happened was using the automated capper. So, forcing the use of gloves is not entirely in our employees' best interest. CNESST didn't see a food safety issue with not wearing gloves, at this point, because of the heat processing kill point which occurs AFTER the cap is put on. As you've noticed, It's not the gloves that are the issue, here, but rather the leftover caps.

I like the idea of throwing out the lids at the end of the shift. That makes excellent sense, in which case I have to figure out how to minimize those losses.

Processing authority? The "processing authority" you suggest occurred in 1982. The only "processing authorities" who have come into our facility for any reason were when we opened this kitchen in 2004, we invited MAPAQ to inspect our kitchen. The fellow laughed at me when I said we had not meat. He closed his clip board and went home. The other visit occurred when a CFIA inspector, a couple of years ago, came as a result of a competitor complaint filed with the "processing authority" and he gave us a pass, raving about how wonderful he found our bain marie heat processing system as our "kill point". The bain marie kill point occurs right AFTER capping. We process everything that comes through our kitchen. I love our kill point, it's the best mitigation. That process has been in successful use without a single recall since 1982.

I will make a point of ensuring that the CAP jug is NOT the same as any of the jugs that are used for processing. Although, if we do, if the PRP includes a sterilization dip of the jug before fetching the caps, that might mitigate THAT risk, yes?



mahantesh.micro

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Posted 10 August 2019 - 04:48 AM

Pepperfire,

You can keep leftover lids in a separate clean and dry LDPE bags and label it with the product name for which you had taken for. Then later you can use these lids next time for the same product for which you had used earlier, this way you can avoid cross contamination.

 

As for lids hygiene is concerned, you are already doing pasteurization/retorting for your product, so no need to worry. 

 

If necessary, air clean the left over lids and sanitize using UV- light (Safety precautions required). Need to develop SOP and for this and validate before implementing.

 

Mahantesh



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Posted 11 August 2019 - 03:32 AM

Hi Pepper,

 

I agree with Mahantesh - keep them in clean, labeled, lined, and fully sealed containers. As an auditor, I would anticipate this as part of your WIP (work in progres) program. Add a written process on how you will rotate the storage bins out to ensure each is washed/sanitized on a routine basis.  

 

PS - I think there is a larger risk with using "a clean beer jug to get the lids out of the lid box" if you are scooping into it with a glass/hard plastic jug. 

 



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Posted 12 August 2019 - 11:41 AM

We are a 1200 sq ft. hand batch facility. We do have nationally distributing clients, but we specialize in sometimes as few as a few dozen bottles per batch. One of our products includes hand stuffing garlic scapes into jars. Many of the client products are just not suitable to machine capping. It's one of the reasons why we decided to go with FSSC for our standard so we could be sure to mitigate any and all risks.

We have been doing this hand capping for over 40 years, and so far, the physical risk with this process is blisters. We have as yet not had anyone cut themselves to bleed during the bottling process, EXCEPT once when using an automated capper, and that came as a direct result of a defective bottle that had the neck snap off and the hand holding the bottle got cut. The SOP for using the automated capper isn't my issue, here.

We are doing a large variety of processed products, specifically targeting small batch customers, so it is imperative that we have PRPs that suit all situations, but I can never make all situations fit an automated capper, it won't happen, some packages require hand capping. The goal of our business is to ensure that handmade products can remain in business. Big Food has a bad habit of mainstreaming everyone into a million bottle filling line. THAT isn't our market. Some little old ladies want to keep selling their hand-picked wild strawberry jam safely, and we are their only support. So our goal is to maintain the small hand capping standard. In order to do that.

CNESST determined that the gloves are a worse if not the same physical hazard to the employee than the not wearing of them, short of a breakage incident happening, and as I said, the only time that ever happened was using the automated capper. So, forcing the use of gloves is not entirely in our employees' best interest. CNESST didn't see a food safety issue with not wearing gloves, at this point, because of the heat processing kill point which occurs AFTER the cap is put on. As you've noticed, It's not the gloves that are the issue, here, but rather the leftover caps.

I like the idea of throwing out the lids at the end of the shift. That makes excellent sense, in which case I have to figure out how to minimize those losses.

Processing authority? The "processing authority" you suggest occurred in 1982. The only "processing authorities" who have come into our facility for any reason were when we opened this kitchen in 2004, we invited MAPAQ to inspect our kitchen. The fellow laughed at me when I said we had not meat. He closed his clip board and went home. The other visit occurred when a CFIA inspector, a couple of years ago, came as a result of a competitor complaint filed with the "processing authority" and he gave us a pass, raving about how wonderful he found our bain marie heat processing system as our "kill point". The bain marie kill point occurs right AFTER capping. We process everything that comes through our kitchen. I love our kill point, it's the best mitigation. That process has been in successful use without a single recall since 1982.

I will make a point of ensuring that the CAP jug is NOT the same as any of the jugs that are used for processing. Although, if we do, if the PRP includes a sterilization dip of the jug before fetching the caps, that might mitigate THAT risk, yes?

 

Hi Pepperfire,

 

As your profile just states "Earth" I made the assumption you might be affiliated with the FDA (where in the US we do have scheduled processes for the higher risk foods). However, it sounds like you are not. So you wouldn't have to worry about that. Your kill point does happen after capping, so you would be mitigating the risks of handling the bottles.

 

Based on your description, the company you work for is very small; whereas I've mostly been affiliated with mid-sized companies that can't afford to cap bottles by hand; otherwise definitely risking hand injuries with 20-30 bottles coming down the line per minute. it sounds like you are a small batch operation so keep doing what you do.

 

Also, when I mention gloves, most of the companies I've been affiliated with had kill-steps prior to capping, so handling at the back-end of the process is very important. I still do like the use of gloves even though I have heard many times otherwise about gloves being less sanitary and so forth. Just my personal opinion that if GMPs are handled appropriately, I would recommend gloves.

 

Regarding your scoop jug, I still don't think you could get away with risk assessing it, because auditors are looking specifically at intended use. Are you using the jug as it was intended to be used per your process? If not, then an auditor can get you. Not saying they will, but I have seen it happen.

 

 

Mahantesh brings up good points as well. You can look at bagging and sterilizing, or just keeping enough lids on the line so that by the end of the day if you have to throw anything away, it's a bare minimum. Either way, I don't think you have much risk as your capping happens before kill-step.



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Posted 12 August 2019 - 12:07 PM

Facility I was at (certified SQF) auditor had no issue with hand capping due to the time/temp pasteurization of all products. As far as I'm concerned, this is a none issue and you shouldn't be throwing out the lids at end of day.  PROVIDED you have a validated process for all jars and all skus and your pH is low enough


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Posted 12 August 2019 - 03:54 PM

Hi Pepperfire,

 

As your profile just states "Earth" I made the assumption you might be affiliated with the FDA (where in the US we do have scheduled processes for the higher risk foods). 

I hadn't thought about that. I am going to adjust my profile. I am indeed Canadian, and we do have a couple of clients on the low end exporting to the US, but they have to comply with FDA rules by July 2020, I believe. I am so glad, right now, that my Auditor is a US cross-border specialist. <3

Also, Ugh, I hadn't even been considering the US regs as we are writing this! I am going to have to redo some decision trees.



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Posted 12 August 2019 - 04:21 PM

I hadn't thought about that. I am going to adjust my profile. I am indeed Canadian, and we do have a couple of clients on the low end exporting to the US, but they have to comply with FDA rules by July 2020, I believe. I am so glad, right now, that my Auditor is a US cross-border specialist. <3

Also, Ugh, I hadn't even been considering the US regs as we are writing this! I am going to have to redo some decision trees.

  Gotta love the FDA. Anyway, I think you did a great job risk assessing your process, and I think that if brought up by anyone, they'd understand you have mitigated your risks. Once you explained your kill-step, there's no reason to suggest you change up your process. As Scampi said, be sure you have the validations to back up your statements. 

 

I'm personally a stickler for handling (so I'd still think about the possibility of discarding the leftover caps), but that doesn't mean you need to be. You've got a well-thought out process, and I think if you've provided all the data to back up your conclusions, you shouldn't need to change anything on your capping process.



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Pepperfire

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Posted 12 August 2019 - 04:27 PM

Thanks everyone. I am so glad this forum exists! I don't know how I would be able to do this without all of your help!!





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