15 replies to this topic

[peipei]

Good morning, we just had a audit for our SQF and GFCP certification. The auditor gave us a non-conformity because the oven gloves/oven mitts were in contact with food contact surface when the employees were de-panning the breads. The gloves/mitts are used to pull out the baking racks out from the oven and to de-pan the breads. Does anyone have any suggestion as to how we can resolve this non-conformity? The gloves are porous, so I'm not sure if cleaning will actually be suitable or even do a proper cleaning. We were told that we could do a risk assessment to justify that it is ok to be in contact with food contact surface. However, I'm not sure how to go about. Note: I haven't posted in the forum for a long time. Please let me know if this is posted at the wrong place. I will repost it elsewhere. Feedback is greatly appreciated! Thank you!

[Scampi]

Talk to a lab and find out how to sample the surface of the oven mitts. Depending on what you find, you can use the results to base your risk assessment off of. 

The findings, plus GMPs and sanitation program should  result in the conclusion that they are safe to use

 

Also, the trays are undergoing a kill step next pass through the oven, so any microbes on the food contact surface shall be killed

 

 

Auditor must really have been trying to find something!

[peipei]

Thanks Scampi for your feedback.

 

Like I said, cleaning the gloves is possible not but possible at the same time?

The gloves are porous... so I'm not sure how is it even possible to do a proper cleaning of the gloves? 

In addition, we also have one mitt that is in fabric. We don't have an on site laundry cleaning.

 

Cleaning the de-panning station is usually done at the end of the day.

I don't think cleaning the de-panning table would be cost efficient when it is done at almost every hour.

 

I will definitely talk to a lab and see what we can do.

 

We are also thinking about renting oven gloves but I wonder if it will actually resolve the issue because the glove will still be touching the table?

Or would it be more acceptable because a new clean glove is used to de-pan every day?

[Scampi]

I wouldn't change a thing honestly  If you get one minor every year for this....it's not worth the energy IMHO  and I know bakers prefer the pans be washed less frequently not more (like confections)

 

AIB may have some info----they used to be the international bakers association..

 

Some minors really aren't work investing a lot of energy

 

I would send my CAs back as food contact surfaces have another kill step applied once used, or something like that as a really simple explanation/risk assessment

 

Do not change your process as the first option. Has there EVER been a pathogenic bacteria recall in baked goods (without filling/icing)????

[SQFconsultant]

The auditor gave us a non-conformity because the oven gloves/oven mitts were in contact with food contact surface when the employees were de-panning the breads.

 

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,

 

From this i take it the gloves/mitt was NOT in contact with food product directly and was in contact with food contact pans, equipment.

 

Did the Auditor review your cleaning for the pans/equipment, etc.?

 

Frankly, I think it is a pretty lame call.

 

And, yes an RA would take care of that.

[peipei]

The oven gloves/mitts do not touch directly the food.

They are used only to take out the racks from the oven and to de-pan the breads onto a stainless table.

 

No auditor has mentioned this was an issue in the past audit.

We were taken by surprise when the auditor mentioned that the gloves are touching the de-panning table is a non-conformity.

 

I was discussing with the president in regards in doing microbial swabs on the glove and tables to see if there are any risk over time.

However, she believe this is a waste or money and time.

Anyone has any idea, on how to do this risk assessment other than microbial testing?

 

I would love to find a permanent solution but for now, we are just doing a training with the employees and have them understand that they need to put the gloves at the bottom shelf of the table. That being said, all employees understand the new procedure but I'm sure there will be times where they will just leave the mitts on the table (too much frequent bending to get the gloves).

[Scampi]

here is our risk assessment template

 

has worked for SQF and CFIA

 

Column E will generate a risk value for you

 

You decide what you believe the risks are and then attach the designated value to likelihood of happening and severity .  The lower the overall risk value, the better shape you are in

Attached Files

•  RA.xlsx   13.98KB   41 downloads

Edited by Scampi, 04 February 2021 - 09:05 PM.

[The Food Scientist]

Looks like your auditor was trying to *find something* . I would definitely go ahead and do RA.

 

Had almost the same issue with an auditor about aprons. I informed her they get laundered on site daily. She still took a point out because they *touched* the tables where food was (raw food and not even baked). So I did a RA. she was okay with it.

[peipei]

here is our risk assessment template

 

has worked for SQF and CFIA

 

Column E will generate a risk value for you

 

You decide what you believe the risks are and then attach the designated value to likelihood of happening and severity .  The lower the overall risk value, the better shape you are in

 

Hi Scampi,

 

Thank you for your RA template.

 

Sorry if I sound stupid/unknowledgeable... maybe it's too early in the morning and I can't think straight.

 

I see that you have 2 column for Hazards.

I assume one of the column is to identify what kind of hazards (bacterial proliferation, material degrading...).

Is the second column for "what could be the cause"?

 

Also, you have a section for "control strategy" in your risk assessment.

What kind of control could it be?

As far as it goes right now, I don't see a control strategy?

I mean while de-panning, for sure the gloves are going to touch the table or even be placed on side of the table (allowing the employee to place the hot bread onto a rack for cooling).

[Scampi]

You know the only people who drink more coffee than Canadians are the Scandinavians right?  Working on #4 as I type lol 

 

Column two is to detail what the hazard type specifics may be

 

The control is the heat of the pans. There may have been bacteria on the mitts, but the high temp of the pans should kill it instantly, plus the bread is obviously screaming hot as well, so one could assume the same should there be any (nonexistent) transfer from mitts to table and table to bread

 

If you have a infrared thermometer or can get your hands on one, take the surface temp of the bread at depanning-you should be able to cross reference that against the minimum temperature of what bacteria you think may be involved would be inactivated--voila your done!

[peipei]

I didn't know the Scandinavians drink a lot of coffee... lol
 
Is actually the heat of the pan really a good or feasible control?
The production room is at a cool temperature... so I can only assume that the pans will cool down quickly or fairly fast enough.
The first few pans might be very hot to de-pan... but as the employee de-pan and place the breads on a cooling rack, the other pans would continuously cool down...
 
I wish I have an infrared thermometer so that I can take the surface temperature...
In no way, I will be able to get an infrared... anything that cost money is out of the question.

[Scampi]

I hear that----current employer is such a refreshing change in the finance department!!!

 

When the pans get used again, the over temp should be hot enough to kill anything that may ---see link for kill step calculator for baking from AIB

 

 

https://www.aibinter...tep-Calculators

 

You could use your probe thermometer, you'll just have to discard? the test pieces

 

Swab the table mid shift for ATP and before cleaning and after cleaning---make it pretty data, add in the lack of recalls and you're RA should be complete

[peipei]

OMG...

I wish I could do all of that....

 

The owner refuses to discard any products!

And there is no ATP swabs over here.... literally refused upon suggestion, even for allergen swab.

[Scampi]

whoa

 

 

you are definitely not working for Weston's or dimpflmeier!!!!!!!!!!!!

 

Ok, your next plan of attack that costs zero dollars is to argue the non conformance with the auditing body

 

You can put a risk assessment together based on scientific papers and info from AIB and cross your fingers

 

And in your spare time (HAHAHAHA) put together a cost benefit analysis of what ATP swabs costs vs what a recall would cost (finance can help) and tell the owner they are a must!!  Put your foot down backed by $$$$$$$$$$$$$  the only language lot of owners understand

 

Good luck!!!!!!!!

[peipei]

I'm definitely not working for those 2 companies.

We are actually a very very small bakery... we are a total of 6 employees (from management to shipping)

 

I found 2 articles from AIB website in regards to the baking temperature kill step for Hamburger Buns and Plain Muffins (at least applicable to our facility)

It mentions at a temperature of 190 degree Celsius for 17min would ensure >5 log reduction in Salmonella for Muffins and 218 degree Celsius for at least 9 min would eliminate Salmonella population by > 6 logs.

 

But during the audit, the auditor asked the owner if there is a record of temperature monitoring for the oven and product temperature, and she replied no because she has a risk assessment from Environex stating that baking is not a CCP. That risk assessment was given to the auditor and he did not acknowledge the risk assessment completely because we still didn't take temperature to ensure that the temperature of the oven is what is stated on the screen and that the temperature of the bread is at least of 90.

She mentioned that if the bread is not cooked, then the appearance would look off and the inside of the bread would be sticky. The auditor's reply was that she is making a subjective argument (based on quality/appearance) and not actual facts/numbers.

 

I'm not saying the auditor is wrong or being harsh but... what he mentions make sense as well..

How do you know that the actual temperature is what it's stated on the screen and that your internal temperature is actually 90?

The temperature probe of the oven may be faulty as well... who knows?

 

Her argument would be in regards to the swabs would be... I haven't had a recall ever since I was in operation and cannot have imagine having a recall because all her products are baked and frozen solid.

Then asking her to call technician in to do preventive maintenance, she would say she doesn't need it because the machine is still working. No need to waste money and I don't have the money right now =_=

[peipei]

Anyone wants to put some input in my risk assessment?

 

 

 

Likelihood

Severity

Risk

Control

Biological

Bacterial Proliferation / Bacterial cross-contamination from the gloves/mitts to food contact surface

1

3

3

Heat from the pan and racks coming out of the oven.

Biological

Bacterial contamination from employee handling

1

3

3

GMP / Training

Allergen

Allergen cross-contamination

1

3

3

Separate oven mitts/ gloves

Cleaning records

Allergen Control Program

Physical

Deterioration of the oven gloves/mitts

1

2

2

Inspection of working tools before use.