We are having a healthy discussion/debate about the interpretation of parts of the Juice HACCP regulation, specifically 21CFR120.6. If you read below, it states what you have to do, and that you have to do it before, during and after processing. What is your interpretation of "before, during and after?"
Our debate is whether it means:
A. We use a checklist of the 8 items and do them 3 times every day (or every day you manufacture juice) - before we start processing, while we are processing, and after processing stops.
B. We use our routine monitoring of the 8 key items, for which there are already established procedures and records, but may not be daily.
If we already do all these things, do we need to do them to three times a day/shift? I'm struggling. A combination of A and B seems reasonable, but we're not sure. What are your thoughts?
§120.6 Sanitation standard operating procedures.
(a) Sanitation controls. Each processor shall have and implement a sanitation standard operating procedure (SSOP) that addresses sanitation conditions and practices before, during, and after processing.
(1) Safety of the water that comes into contact with food or food contact surfaces or that is used in the manufacture of ice;
(2) Condition and cleanliness of food contact surfaces, including utensils, gloves, and outer garments;
(3) Prevention of cross contamination from insanitary objects to food, food packaging material, and other food contact surfaces, including utensils, gloves, and outer garments, and from raw product to processed product;
(4) Maintenance of hand washing, hand sanitizing, and toilet facilities;
(5) Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants;
(6) Proper labeling, storage, and use of toxic compounds;
(7) Control of employee health conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces; and
(8) Exclusion of pests from the food plant.
(b) Monitoring. The processor shall monitor the conditions and practices during processing with sufficient frequency to ensure, at a minimum, conformance with those conditions and practices specified in part 110 of this chapter and in subpart B of part 117 of this chapter that are appropriate both to the plant and to the food being processed. Each processor shall correct, in a timely manner, those conditions and practices that are not met.