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Can you stage product in the production room while Pre-Op is going on with a USDA inspector present?

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#1 rgiuliano137

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Posted 21 May 2020 - 06:30 PM

Can you stage product in the production room while Pre-Op is going on with a USDA inspector present?



#2 olenazh

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Posted 21 May 2020 - 06:41 PM

Pre-Op inspection is done prior to starting operations to ensure cleanliness, GMP, hygiene, equipment functionality, etc.



#3 rgiuliano137

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Posted 21 May 2020 - 06:48 PM

had to ask, the owner wants to use production room as a cooler and wants to stage product, even during pre-op, the inspector is not too happy with this.



#4 SQFconsultant

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Posted 21 May 2020 - 06:50 PM

Can you stage product in the production room while Pre-Op is going on with a USDA inspector present?

 

You might need to clarify for me - what I get from your message is that you want to know if you can bring in product while a pre-op is underway with a USDA inspector present?  If that is the case - no.

 

If on the other hand you meant that your stage product was placed the day or evening before, is present, wrapped up and ready to go and then you have a pre-op done with a USDA inspector present - the answer is YES, but only if the stage product is sealed.  There is a possibility of getting some flack on this from the USDA - they are not (like auditors) all the same mindset.


Edited by SQFconsultant, 21 May 2020 - 06:52 PM.

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#5 rgiuliano137

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Posted 21 May 2020 - 06:54 PM

Glenn, correct, product would be staged a night before, yes wrapped and unexposed raw material, however the USDA inspector still frowns on this. 



#6 olenazh

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Posted 21 May 2020 - 06:59 PM

Did the inspector explain the reasons for objections? just out of curiosity...



#7 MsMars

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Posted 22 May 2020 - 01:44 PM

had to ask, the owner wants to use production room as a cooler and wants to stage product, even during pre-op, the inspector is not too happy with this.

 

Does the staged product interfere with the inspectors ability to do a thorough inspection? Does it block critical areas of inspection?



#8 rgiuliano137

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Posted 22 May 2020 - 01:54 PM

No Inspector did not explain her reasoning to why she does not want product staged in the production room, however i was ask her to provide the Regulation as to why i cannot stage product overnight, product will be sealed and we are just staging it to defrost a bit to make it sliceable.



#9 olenazh

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Posted 22 May 2020 - 02:06 PM

No Inspector did not explain her reasoning to why she does not want product staged in the production room, however i was ask her to provide the Regulation as to why i cannot stage product overnight, product will be sealed and we are just staging it to defrost a bit to make it sliceable.

I have no experience dealing with USDA inspectors, but don't think they differ from CFIA ones. So, I've never (for my 10-year experience in QA control, having 2 clients in food industry) met a CFIA inspector refusing to provide a reason for objection and refer to corresponding regulatory standard. However, we always have an option to object inspector's qualification & file a complaint, don't we?



#10 rgiuliano137

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Posted 22 May 2020 - 04:22 PM

Yes on filing a complaint!!



#11 SausageGuy

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Posted 22 May 2020 - 04:45 PM

product will be sealed and we are just staging it to defrost a bit to make it sliceable.

 

This sounds like it could be considered a thawing procedure. I would write a SOP for staging overnight, and include leaving it in the production room (as long as the temp is below 40F). Our inspector wanted us to add it to our flow chart and do a hazard analysis for that step, which we did. It was an easy fix. Not too many hazards with leaving sealed product in a refrigerated room overnight.



#12 FurFarmandFork

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Posted 26 May 2020 - 08:38 PM

Questions above were spot on:

What's the risk,

Does having it there interfere with either the pre-op activities (e.g. cleaning) or inspection activities

Do you have this written into your procedure with requirements (e.g. "cannot open and expose product until Pre-op is completed, but may store in the room")

 

Then go ahead and work with your inspector to make them say exactly why they take issue, not just their preference or opinion but the risk created or the code violated.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.





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