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Environmental swab positive in low-risk RTE food

environmental mointoring honey

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#1 BostonCream

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Posted 04 December 2019 - 05:53 PM

Hi folks,

 

I recently moved from RTE meat plant to a honey plant, and am confused about this "low aw, low pH, low risk" honey production.

In RTE meat, we used to test every batch of finished product, in addition to bi-weekly env swab. Here in honey plant, there's no finished product testing (since the characteristics of honey does not support pathogen growth).

 

 

When we try to build a EMP from scratch, questions come:

- Based on risk analysis, can we safely schedule only APC/TC/EC/EB swab on zone 1, and Salmonella & Listeria swab on zone 2&3?

- If monthly zone 2 or zone 3 swab found Salmonella positive, what shall we do with the finished product in the past whole month? They will likely be gone to the market already, with no finished product testing. 

 

 

We tried to find some government regulation on this, however HONEY is an exempt from CFIA Listeria policy. So it all depends on what we want to do ourselves and how we validate it.

 

Any thought would be appreciated!


Edited by BostonCream, 04 December 2019 - 05:56 PM.


#2 SQFconsultant

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Posted 04 December 2019 - 06:41 PM

When I first got SQF registered as an auditor someone said, why did you go to the trouble of getting the honey category - you know you'll never use that.

 

Truth be told, I was one of the few auditors that handled honey - thus I was rather busy and as an SQF Consultant when they allowed carry over of FSC's Honey carried over and today we can look back and go, hey that was a good idea, as we've been in a number of real honey houses.

 

Question - is the facility heating the honey or are you processing unheated raw?


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#3 BostonCream

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Posted 04 December 2019 - 06:55 PM

Hi Glenn, good to know that you are in honey category! I agree that there aren't many honey auditors in north America.

We produce both pasteurized liquid honey and raw cream honey.

 

 

When I first got SQF registered as an auditor someone said, why did you go to the trouble of getting the honey category - you know you'll never use that.

 

Truth be told, I was one of the few auditors that handled honey - thus I was rather busy and as an SQF Consultant when they allowed carry over of FSC's Honey carried over and today we can look back and go, hey that was a good idea, as we've been in a number of real honey houses.

 

Question - is the facility heating the honey or are you processing unheated raw?



#4 Charles.C

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Posted 05 December 2019 - 10:55 AM

Hi folks,

 

I recently moved from RTE meat plant to a honey plant, and am confused about this "low aw, low pH, low risk" honey production.

In RTE meat, we used to test every batch of finished product, in addition to bi-weekly env swab. Here in honey plant, there's no finished product testing (since the characteristics of honey does not support pathogen growth).

 

 

When we try to build a EMP from scratch, questions come:

- Based on risk analysis, can we safely schedule only APC/TC/EC/EB swab on zone 1, and Salmonella & Listeria swab on zone 2&3?

- If monthly zone 2 or zone 3 swab found Salmonella positive, what shall we do with the finished product in the past whole month? They will likely be gone to the market already, with no finished product testing. 

 

 

We tried to find some government regulation on this, however HONEY is an exempt from CFIA Listeria policy. So it all depends on what we want to do ourselves and how we validate it.

 

Any thought would be appreciated!

 

^^^ Ahem.

 

https://www.cfs.gov...._Raw_Honey.html


Kind Regards,

 

Charles.C


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#5 sqflady

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Posted 06 December 2019 - 02:12 PM

- Based on risk analysis, can we safely schedule only APC/TC/EC/EB swab on zone 1, and Salmonella & Listeria swab on zone 2&3? YES

- If monthly zone 2 or zone 3 swab found Salmonella positive, what shall we do with the finished product in the past whole month? A positive in zones 2 or 3 does not indicate the product is contaminated.  

 

This is very much like how we operate in the dairy industry.  We only do ATP, APC and coliform swabs in zone 1.



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#6 pjm

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Posted 08 December 2019 - 10:35 PM

I think you have answered your own question - honey does not support pathogen growth, so you don't need an EMP at all!

I used to work in dairy and was slightly shocked to find that this is the case for foods that don't support pathogen growth.

 

The food safety risks of raw honey relate only to toxins from the plants that the bees have foraged on and clostridium botulinum spores that can infect young babies whose gut bacteria haven't yet been established. Neither of these risks will be addressed by an EMP.

 

You should still monitor the general hygiene of your plant of course, this could be done for example by conducting coliform swabs of equipment after cleaning, and air settle plates for total count, yeast and mould, but pathogen swabs are really a waste of time and money in your situation.



#7 Ryan M.

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Posted 09 December 2019 - 03:22 AM

In relation to Charles's post...what processing does the raw cream honey undergo?  Is it filtered?  Heated to any degree?  If heated to what temperature?

 

I think your biggest risk is potential toxins in raw or heated / processed honey.



#8 BostonCream

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Posted 09 December 2019 - 04:15 PM

I think you have answered your own question - honey does not support pathogen growth, so you don't need an EMP at all!

I used to work in dairy and was slightly shocked to find that this is the case for foods that don't support pathogen growth.

 

The food safety risks of raw honey relate only to toxins from the plants that the bees have foraged on and clostridium botulinum spores that can infect young babies whose gut bacteria haven't yet been established. Neither of these risks will be addressed by an EMP.

 

You should still monitor the general hygiene of your plant of course, this could be done for example by conducting coliform swabs of equipment after cleaning, and air settle plates for total count, yeast and mould, but pathogen swabs are really a waste of time and money in your situation.

 

Thanks Pjm, we thought we didn't need a EMP either (we still do a swab for annual validation though), however SQF auditor last year gave a NC for that. I guess the idea is that, even though honey itself doesn't post harm, the moisture introduced from daily cleaning can lead to bacterial growth. What we may do then is to 1) reduce zone 1 cleaning frequency 2) Increase zone 2&3 EMP.

 

 

In relation to Charles's post...what processing does the raw cream honey undergo?  Is it filtered?  Heated to any degree?  If heated to what temperature?

 

I think your biggest risk is potential toxins in raw or heated / processed honey.

 

Hi Ryan, we filter and pasteurize honey to 170F.







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