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5 Log Reduction & Spices/ Marinades

Validation FSMA Spices Marinades Breading

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#1 Njaquino

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Posted 14 August 2019 - 07:26 PM

"The Preventive Controls Rule of the Food Safety Modernization Act (FSMA) requires all food companies to develop a food safety plan in which they identify risks and then implement preventive controls to mitigate risk. Pathogens such as Salmonella are important for the spice industry to consider as they evaluate hazards and ASTA has issued guidance recommending the use of validated microbial reduction processes. FSMA now requires companies to validate these processes." 

 

I am working for a spice/ marinade company. I am creating their HARPC and all things pertaining to quality. I have never designed a 5-log reduction validation study how can I go about it? I know labs can do this for me but I assume they need information. We do not have any kill step that I am aware of. Any help or recommendations would be great!



#2 Hank Major

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Posted 14 August 2019 - 07:31 PM

Well, I would just micro test the marinade before and after I added the vinegar. But maybe that's too simplistic.



#3 Charles.C

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Posted 14 August 2019 - 07:57 PM

"The Preventive Controls Rule of the Food Safety Modernization Act (FSMA) requires all food companies to develop a food safety plan in which they identify risks and then implement preventive controls to mitigate risk. Pathogens such as Salmonella are important for the spice industry to consider as they evaluate hazards and ASTA has issued guidance recommending the use of validated microbial reduction processes. FSMA now requires companies to validate these processes." 

 

I am working for a spice/ marinade company. I am creating their HARPC and all things pertaining to quality. I have never designed a 5-log reduction validation study how can I go about it? I know labs can do this for me but I assume they need information. We do not have any kill step that I am aware of. Any help or recommendations would be great!

 

Do ASTA also agree that you require/can achieve a 5-log Reduction + validation for yr Process ?. (IMO [not a Spice Person] not likely to be so easy in the absence of a "killing" step)


Kind Regards,

 

Charles.C


#4 Njaquino

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Posted 14 August 2019 - 08:16 PM

Well, I would just micro test the marinade before and after I added the vinegar. But maybe that's too simplistic.

Well right now we are testing every batch of marinade for pathogen (Salmonella, Listeria & APC)

 

I come from beverage manufacturing and we had a validation study that told us our pH needed to be below a certain number, which I then set as a CCP. 



#5 Njaquino

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Posted 14 August 2019 - 08:23 PM

Do ASTA also agree that you require/can achieve a 5-log Reduction + validation for yr Process ?. (IMO [not a Spice Person] not likely to be so easy in the absence of a "killing" step)

 

I can't access their guidance form until I am a member. Which I am currently working on getting in. 



#6 Hank Major

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Posted 14 August 2019 - 08:37 PM

I can't access their guidance form until I am a member. Which I am currently working on getting in. 

 

I'm sure ASTA doesn't specify a particular log number.

 

And wouldn't you say that adding vinegar and salt is your kill step?



#7 Njaquino

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Posted 14 August 2019 - 08:41 PM

I'm sure ASTA doesn't specify a particular log number.

 

And wouldn't you say that adding vinegar and salt is your kill step?

Yes, but I would need to have it scientifically proven by a certified lab right? 



#8 Charles.C

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Posted 14 August 2019 - 08:44 PM

Hi Njaquino,

 

I daresay the marinade / design requirements may also relate to what is being marinaded/processed.

 

eg this attachment, pg 15 -

 

Attached File  Salmonella-Compliance-Guideline-SVSP-RTE-Appendix-A.pdf   783.66KB   25 downloads


Kind Regards,

 

Charles.C


#9 Hank Major

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Posted 14 August 2019 - 08:49 PM

Sending out samples to a certified laboratory is, of course, desirable for Validation.  I am curious about the dirtiness and the exact microbial fauna of the raw materials and why you think 5 logs is the goal.  For example, black pepper often has a very high TPC, but very rarely has pathogenic bacterial species.  Garlic powder has high TPCs and often has coliforms.  I would re-examine my thinking on what hazards you are trying to control, and (for example) request low-bac raw materials from your suppliers. 



#10 Njaquino

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Posted 14 August 2019 - 11:38 PM

Sending out samples to a certified laboratory is, of course, desirable for Validation.  I am curious about the dirtiness and the exact microbial fauna of the raw materials and why you think 5 logs is the goal.  For example, black pepper often has a very high TPC, but very rarely has pathogenic bacterial species.  Garlic powder has high TPCs and often has coliforms.  I would re-examine my thinking on what hazards you are trying to control, and (for example) request low-bac raw materials from your suppliers. 

 

Well I was under the understanding that a 5 log was required in general but maybe that only pertains to juice HACCP. The company has accepted things prior to me coming, of 100,000 CFU/g APC.



#11 Hank Major

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Posted 14 August 2019 - 11:46 PM

For me, Total Plate Count is merely an indicator of the general cleanliness of the raw material, and no Critical Limits are imposed.  I use TPC for statistical purposes since a thousand COAs saying 'Negative'  for E. coli and Salmonella are statistically useless. 



#12 Scampi

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Posted 15 August 2019 - 11:59 AM

5 log reduction number is whats required for low acid and/or acidified foods

 

This study is NOT something you should be doing on your own

 

If your spices are not irradiated prior to you receiving them, you could only achieve a 5 log reduction if the pathogen level was known.

 

More information needed please


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#13 kfromNE

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Posted 15 August 2019 - 12:13 PM

Another way to validate your process is to find a scientific study. When I worked for a sauce company that's what we did. This was based upon acidity and cooking temperature. Not sure what's out there but google scholar might be a place to look. Another way would be to talk/email your local university with a food science department to see if they know of any studies or information. This was the route I had taken. The bonus: it was free.

 

Another option, if the company is a small business, check with your state extension. Many state extensions have resources for small business especially in the food industry.



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#14 KSR

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Posted 22 August 2019 - 05:15 PM

Are you producing a acidified food (ph < 4.6, Aw > 0.85)?   Or is it just the spice / seasoning blend that water and other liquids are added by the customer??  acidified foods require registration, scheduled process, specific training, etc. 

 

 

https://fbns.ncsu.ed...g_dressings.pdf

 

https://www.accessda...rt=114&showFR=1



#15 KSR

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Posted 22 August 2019 - 05:18 PM

Sending out samples to a certified laboratory is, of course, desirable for Validation.  I am curious about the dirtiness and the exact microbial fauna of the raw materials and why you think 5 logs is the goal.  For example, black pepper often has a very high TPC, but very rarely has pathogenic bacterial species.  Garlic powder has high TPCs and often has coliforms.  I would re-examine my thinking on what hazards you are trying to control, and (for example) request low-bac raw materials from your suppliers. 

 

spices are routinely implicated in food borne illness.    https://www.foodpois...-contamination/



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#16 Njaquino

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Posted 22 August 2019 - 08:19 PM

5 log reduction number is whats required for low acid and/or acidified foods

 

This study is NOT something you should be doing on your own

 

If your spices are not irradiated prior to you receiving them, you could only achieve a 5 log reduction if the pathogen level was known.

 

More information needed please

 

Okay so we do not irradiate the spices. The specs we have from the supplier only specify that they do foreign material checks.



#17 Njaquino

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Posted 22 August 2019 - 08:20 PM

Another way to validate your process is to find a scientific study. When I worked for a sauce company that's what we did. This was based upon acidity and cooking temperature. Not sure what's out there but google scholar might be a place to look. Another way would be to talk/email your local university with a food science department to see if they know of any studies or information. This was the route I had taken. The bonus: it was free.

 

Another option, if the company is a small business, check with your state extension. Many state extensions have resources for small business especially in the food industry.

 

We are a small company. We do not have a cook step but I will look into this for the marinades. 



#18 Njaquino

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Posted 22 August 2019 - 08:22 PM

Are you producing a acidified food (ph < 4.6, Aw > 0.85)?   Or is it just the spice / seasoning blend that water and other liquids are added by the customer??  acidified foods require registration, scheduled process, specific training, etc. 

 

 

https://fbns.ncsu.ed...g_dressings.pdf

 

https://www.accessda...rt=114&showFR=1

 

The company has never tested pH. The spice/ seasonings are dry. The marinades contain vinegar but I don't think it is enough to bring the pH that low. I can check this. 

 

I was in a fermented beverage and I remember our CCP was at <3.1 because of a validation study we conducted through a lab. 



#19 Scampi

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Posted 23 August 2019 - 12:25 PM

Since the spices are not going through a kill step, you may want to consider having the raw materials tested in a lab prior to use. I personnally would force the supplier to do this for you..................foreign materials great, but not the real risk here

 

Lots of spices pose pathogenic risks, that is why lots are irradiated..................perhaps they dry steam instead?  I would be insisting on "clean" ingredients with a CoA


Because we always have is never an appropriate response!


#20 Charles.C

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Posted 23 August 2019 - 04:54 PM

Hi Njaquino,

 

 I suggest you should  preferably verify that you are actually obliged to achieve a 5log reduction as being discussed The attachment in my earlier post indicates that, depending on the (validated) process, such an action might in practice be unnecessary.

 

Processes such as being discussed in this thread sound analogous to the "disinfection" stages in Production of RTE, Fresh Produce which afaik are typically not required to demonstrate/validate the achievance of comparable pathogen reductions.


Kind Regards,

 

Charles.C


#21 Fishlady

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Posted 24 August 2019 - 08:28 PM

I would suggest talking to a recognized process authority. There are various private companies, trade organizations, and state extension programs who could help you.



#22 DECLEMY Benoit

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Posted 15 October 2019 - 12:28 PM

Hi Commuity,

 

I think we can help on this topic and bring some advise in term of validation rpocess and achieve a 5 log reduction.

We are a recognized process authority for low moisture food validations / dry ingredients. We are doing a lot of work on nuts, spices, plant-based ingredients (soy, pea etc.) for instance. Most of these validations are actually conducted with a surrogate organism. The use of a surrogate is a very well established practice for these categories with a strong recognition by regulatory authorities. Most of our projects are US-driven validations, so FDA has already reviewed some of our reports. Another validation methodology that we can use is process measures (like time, temperature) combined with lab-generated D- and z-value models. To fully answer your question, what type of validations do you most frequently conduct? And which ones would you be interested in?

I will be happy to organize a call with you to explain our approach

 

Best regards







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