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Pork Rinds, responsibility for pathogen testing when we only resell?


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#1 The Food Scientist

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Posted 18 February 2020 - 09:06 PM

Hi all, I need some insight as I never had worked in a USDA regulated facility and do not have that much knowledge.

 

So we "resell" Pork Rinds (Pork skins called also). We buy ones that are fried, and ones that are dried. 

 

We just resell them, we dont process them or anything in our facility.

 

I requested COAs from them for pathogen testing and this was their response:

 

"Yes, we can accommodate the request and provide a COA for all lots and products we supply to you,,

 

 

For their micro testing list will be $300.00 flat charge per product and per lot.

 

Coliform/E.Coli

Coagulase Positive S. aureus

Salmonella

Listeria monocytogenes

 

Since we are testing for pathogens, per USDA regulation we must held the product in our premises until lab results are proven negative, the control of product until lab reports are available will take between 5 to 7 days and we will charge storage per pallet per day, pricing will be provided at a later date.

 

Micro testing will have to be requested on each order,  unless otherwise indicated by the customer".

 

Since they are USDA regulated, I would imagine they ALREADY do those tests themselves anyway. and they have those COAs, right? (I could be wrong). Then why are they charging us for the tests, the storage (not to mention the insane amount)? Shouldn't they already be doing them? I don't get it.

 

One option I had is that we receive the products, and I pull samples and send them to our 3rd party lab (our cost of those tests are cheaper). And I hold them until results are negative.

 

Can anyone help me? Is it correct what they are saying? USDA folks, help :)


Edited by The Food Scientist, 18 February 2020 - 09:12 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#2 The Food Scientist

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Posted 18 February 2020 - 09:18 PM

All my questions lately have been supplier related! I have been working at my company for about a year now and they had no control over Suppliers and their Supplier Approval Program was almost non-existent. We are getting better but ugh I didn't know it would be this frustrating !

 

- Just a small complaint.  :silly:


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#3 MsMars

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Posted 18 February 2020 - 09:21 PM

Are you repackaging the product? Or are you acting as a warehouse/distributor?



#4 The Food Scientist

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Posted 18 February 2020 - 09:28 PM

Are you repackaging the product? Or are you acting as a warehouse/distributor?

 

A warehouse/distributor. We just receive as is and redistribute without opening or processing.


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#5 MsMars

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Posted 18 February 2020 - 09:36 PM

Since the product is not exposed in your facility, I do not think you need to have a COA which includes pathogen testing on every lot - that would be the responsibility of the manufacturer to have those records. 

 

Edit: Clarification also - they probably do not test for pathogens on finished products for positive release, only indicators.  This is common practice in RTE foods. I'm surprised they agreed to test for you, and they are probably figuring in the cost of test/hold into the fees that they look to collect from you.


Edited by MsMars, 18 February 2020 - 09:40 PM.


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#6 The Food Scientist

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Posted 18 February 2020 - 09:49 PM

Since the product is not exposed in your facility, I do not think you need to have a COA which includes pathogen testing on every lot - that would be the responsibility of the manufacturer to have those records. 

 

 

 

I would have thought so too. They would not "Send it" (release) it to us unless it was positively released. So any issue would be their responsibility I would assume.

 

 

Edit: Clarification also - they probably do not test for pathogens on finished products for positive release, only indicators.  This is common practice in RTE foods. I'm surprised they agreed to test for you, and they are probably figuring in the cost of test/hold into the fees that they look to collect from you.

 

 

Hmm yes. But perhaps post processing(Frying/drying) contamination could occur, so pathogen testing for RTE in this case couldbe needed? I am not really knowledgeable in Meats & Meat products I could be wrong.  LOL The storage cost is ridiculous! 

 

I would think I can obtain a letter of gurantee from them and it will do. But for our internal records (federal laws/regulations and GFSI), I still need a COA from them? Maybe an APC would or something...


Edited by The Food Scientist, 18 February 2020 - 09:51 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#7 MsMars

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Posted 18 February 2020 - 10:25 PM

 

Hmm yes. But perhaps post processing(Frying/drying) contamination could occur, so pathogen testing for RTE in this case couldbe needed? I am not really knowledgeable in Meats & Meat products I could be wrong.  LOL The storage cost is ridiculous! 

 

I would think I can obtain a letter of gurantee from them and it will do. But for our internal records (federal laws/regulations and GFSI), I still need a COA from them? Maybe an APC would or something...

 

Typically positive release testing is focused on the post-lethality "clean" areas prior and during packaging.  A facility must be able to prove that they have mitigated risk of contamination post-lethality to be in compliance with regulations. 

 

I would request COAs from your supplier which reflect the routine testing they perform on their own product; this is not an unreasonable request and depending on how your program is written, this should suffice. 


Edited by MsMars, 18 February 2020 - 10:27 PM.


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#8 Charles.C

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Posted 19 February 2020 - 07:31 PM

I would have thought so too. They would not "Send it" (release) it to us unless it was positively released. So any issue would be their responsibility I would assume.

 

 

 

Hmm yes. But perhaps post processing(Frying/drying) contamination could occur, so pathogen testing for RTE in this case couldbe needed? I am not really knowledgeable in Meats & Meat products I could be wrong.  LOL The storage cost is ridiculous! 

 

I would think I can obtain a letter of gurantee from them and it will do. But for our internal records (federal laws/regulations and GFSI), I still need a COA from them? Maybe an APC would or something...

 

^^^^^(red) I predict any feds involvement  will focus on pathogens although maybe not on every lot if you have sufficient accumulated negative data.

 

L.mono is of course the favorite post-lethality step pathogen to be investigated but maybe not if yr process is fully dry ?


Kind Regards,

 

Charles.C


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#9 TimG

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Posted 19 February 2020 - 08:25 PM

Having worked briefly in the warehousing/distribution side, I can say we never had, nor were we required to, request CoA's for products that came to us packaged, stayed packaged, and left packaged (box in box out).

The focus there was maintaining the documentation to prove that transportation and storage requirements were kept controlled (cold chain for perishables, truck inspections, etc).  We did have pretty robust contracts that put the liability for food safety which was out of our control (pathogens or other biological not related to our own improper storage) right back on the manufacturer. 

Do you guys relabel/re-brand the product at all?



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#10 Charles.C

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Posted 19 February 2020 - 09:04 PM

Having worked briefly in the warehousing/distribution side, I can say we never had, nor were we required to, request CoA's for products that came to us packaged, stayed packaged, and left packaged (box in box out).

The focus there was maintaining the documentation to prove that transportation and storage requirements were kept controlled (cold chain for perishables, truck inspections, etc).  We did have pretty robust contracts that put the liability for food safety which was out of our control (pathogens or other biological not related to our own improper storage) right back on the manufacturer. 

Do you guys relabel/re-brand the product at all?

 

Hi Tim,

 

Afaik, the initial "attack"  in the event of any consumer-level safety problems is usually at the (visible)  final selling point ? Then it starts bouncing back.

 

Seems like some info./clarity from USDA is urgently needed.


Kind Regards,

 

Charles.C





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