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jcieslowski

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Posted 28 October 2019 - 03:49 PM

I'm pretty new to the world of organic and I'm at a bit of a loss.

 

We are planning to open up a new liquid sugar line.  The process is, in brief, to melt finished RTE sugar into water and ship it.  We only have 1 melting tank, a couple storage tanks, and one set of sealed pipework leading to a discharge point where the trucks are loaded.  

 

We currently use RTE non-organic certified cane sugar (non-GMO project verified).   My boss is asking about us purchasing organic certified RTE cane sugar.  He then went further and asked about using beet sugar on occasion, which IS genetically modified and thus not organic or non-GMO certified.

 

I don't see how we can manage that with all the shared equipment.  Especially in the closed pipework.  I'm not sure if there's anything we can 'flush through' the line that would be able to be validated on all the turns and not ruin the organic status.  But maybe I'm just 'over thinking' how hard it is to remove all the residue from the last batch?

 

Thoughts, insights, and direction are appreciated! 



Njaquino

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Posted 28 October 2019 - 06:43 PM

Hello, 

 

I have mainly worked on dedicated organic facility, this is an interesting question you pose. I have not come across it but based on what I know it may not qualify as organic. I do not know how you could prove that there is no residual. I am thinking of CIPing the system with organic approved chemicals then swabbing. But a swab wouldn't tell you if you have left over non-organic material. 

 

I have asked one of my good friends who work for an organic CB to see if there is any way to get around it. I want to know as well. 



Ryan M.

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Posted 28 October 2019 - 11:14 PM

You have options, but the ease of any of them is dependent on the ease of cleaning your equipment.

 

If you use CIP systems to clean your equipment that is best.  You can do a full cleaning with the CIP between the product types.  You could also use the CIP system to do a rinse to purge all sugar out of the system.  Please note, any cleaning chemicals you use on the equipment have to be organic approved.  If you use a no-rinse sanitizer that must be organic approved as a no-rinse sanitizer, or you will have to do a water flush of the sanitizer (and validate this).

Another alternative is a product purge between the products.  You will have to discard the product purge so there will be some product loss.

 

Any of these alternatives you will have to validate the procedure, document it, and verify it typically annually.

 

The best scenario is to schedule as appropriate if you do full cleaning of equipment.  Clean, organic first, regular sugar, and then beet sugar last.



Njaquino

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Posted 28 October 2019 - 11:35 PM

my friend answered and she deals with companies who do split runs. She said that you can run organic and non organic on the same line as long as you wash with approved sanitizers and cleaners. You then verify it is clean and you can proceed to run your organic. She suggests scheduling organic then non organic. 



QM-OS

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Posted 29 October 2019 - 07:19 AM

We have both organic and non-organic products and the CB are OK with our procedure:

If you have to do both productions during a day, the organic has to be done first. (We have "full" cleaning during the night when there is no production.)

IF there is some sort of mishap and you start with non-organic and then have no other choice but to switch to organic, there has to be a thorough cleaning and verifying inbetween. 

(luckily this isn't the norm, our production is usually done as planned)



jcieslowski

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Posted 29 October 2019 - 12:45 PM

Thanks ya'll.  For those that run both, what are your verification and validation activities for making sure that non-organic is not present before starting up with organic the next day?  



Shabdkaur1

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Posted 29 October 2019 - 03:43 PM

Hello,

 

All great responses, good to know that so many organizations are honoring the Organic Certification process!  I worked in a Certified Organic and Certified Non-GMO Project Verified cereal facility, and we had the yearly audits piggybacked, but always did quite well.  We too started with Organic product first, non-GMO (which is Organic, according to our auditor) followed by non-organic, GMO and so on.  This allowed easier transitions between products.  Our facility had 2 connected building and 5 floors with some product travelling throughout the 5 floors on conveyors and through piping during its processing, so our cleanings were quite detailed.  One thing I did not see mentioned here, was documentation.  Whatever process you follow, make sure you document everything, even if you think you've already documented it, document it again!  Once our schedules were determined and followed, and the cleanings were done, we always had a purge before starting Organic product again.  We usually used raw rice, but if your product is liquid, you don't want to introduce rice.  What you could do, is run Organic sugar through your system, and reserve, say, the first 100 lbs of the Organic sugar you run through, and then make that the first 100 lbs of sugar for your first non-organic batch, after the Organic is finished.  That way, you have cleaned as prescribed, documented everything, completed a purge of your system, and not lost all that much product along the way.

 

Good Luck!



pHruit

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Posted 29 October 2019 - 06:36 PM

Thanks ya'll.  For those that run both, what are your verification and validation activities for making sure that non-organic is not present before starting up with organic the next day?  

What's your normal process for verifying post-clean?

No idea how similar the US NOP requirements are to EU organic, but for what it's worth our certification body is happy with the standard process we use - full CIP, line rinse, visual/sensory inspection of rinse water, ATP (not really relevant for the organic question) and Brix/pH tests to confirm absence of cleaning chemicals and prior product. Given that you're handling sugar that would easily show on a Brix test, I'd have thought a similar approach could work for you?



Charles.C

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Posted 30 October 2019 - 12:19 AM

What's your normal process for verifying post-clean?

No idea how similar the US NOP requirements are to EU organic, but for what it's worth our certification body is happy with the standard process we use - full CIP, line rinse, visual/sensory inspection of rinse water, ATP (not really relevant for the organic question) and Brix/pH tests to confirm absence of cleaning chemicals and prior product. Given that you're handling sugar that would easily show on a Brix test, I'd have thought a similar approach could work for you?

 

Hi pHruit,

 

Indeed, validation appears critical.

 

Just curious, how quantitatively sensitive is a Brix test to "contamination" ? I speculate pH not that sensitive ? Visual/sensory seem "indeterminate" ?.


Kind Regards,

 

Charles.C


Ryan M.

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Posted 30 October 2019 - 01:09 AM

Brix can be very sensitive dependent on sampling and instrumentation.  Our brix meter, refractometer, is capable of 0.02 accuracy.  It has a range from 0 degrees Brix up to 70 degrees Brix.

 

pH would be less useful in my opinion because water pH can vary quite a bit dependent on the water source and facility treatment, and it has a similar range (still different) than sucrose.

 

Hi pHruit,

 

Indeed, validation appears critical.

 

Just curious, how quantitatively sensitive is a Brix test to "contamination" ? I speculate pH not that sensitive ? Visual/sensory seem "indeterminate" ?.


Edited by Ryan M., 30 October 2019 - 01:10 AM.


pHruit

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Posted 30 October 2019 - 08:21 AM

Hi Charles,
Yes, it's far from an "absolute" test - the realistic level of sensitivity/detection is miles away from that which one would want for e.g. allergen testing. But it's a reasonable indicator, in combination with the full CIP records, of "is there any gross level of beverage compound / sugar-containing product in the line".

Similarly pH is again only intended as broad final post-clean verification for cleaning chemicals rather than product - the reference point is determined from the direct water feed each day, so it takes account of the inherent variation in the supply to a reasonable degree.

Visual/sensory is a coarse "have we done anything stupid like forgetting to link part of the system up correctly into the CIP cycle, such that there is still residual product in uncleaned tanks/pipes" - very improbable given the training, records, structure of the plant etc., but always good to check ;)

Again it's all only used in combination with a full CIP process - broadly rinse/caustic/rinse/caustic/rinse/PAA/rinse, also validated for removal of sulphites as part of allergen controls etc. (I wonder if organic will go in the same "absolute absence" direction as allergens? Seems to be becoming an expectation for vegan/vegetarian...).

The first part of the subsequent batch is also sent to drain as well - effectively the bit that interfaces with any residual water in the line plus a healthy extra "just in case" allowance that exceeds the capacity of the pipework concerned.

I'm 100% certain that packed organic product only contains the intended material!






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