3 replies to this topic

[Jon19]

We are a GFSI certified contract powder blending and packaging manufacturer in the United States. Products we manufacture are within the food and dietary supplement industries. We currently wet clean between most products and will only transition without a wet clean if moving from one product to the next where the subsequent product contains all ingredients from the preceding product (ex. Vanilla protein moving to chocolate protein with only addition of ingredients). In this case we would only perform a brush down to minimize potential carry over and prevent affecting the flavor of the 2nd product. We are aware of various methods (other than wet cleaning) used when transitioning between products such as: 1. Dry cleaning. 2. Push throughs (using ingredient found in subsequent product, or salt, sugar, etc). These methods seem to be rather common from what we have heard from other manufacturers and prospective customers, and considerations have included ensuring no flavor, sensory, or functional impacts from product to product. However, we are not certain of the rules / requirements and the acceptability of these methods as it seems these techniques may lead to carry-over from one product to the next which would introduce a possibility of ingredients occurring in subsequent product that aren't listed on the label (mis-labeling). Below are a few initial questions. We want to ensure we are compliant with GFSI and governmental agencies. - What level of clean between products is required / acceptable if assuming both are non-allergen or contain the same allergens, and there are ingredients in the preceding product that are not in the formula for the subsequent product? - Is there a level of acceptable carry-over from preceding to subsequent product? - What is the typical method of verifying cleanliness after a dry clean? (i.e. visually clean, etc) - Should a push-through be with sufficient material to ensure all inside surfaces are "washed" with the push-through material.

[Scampi]

The best way (IMO) to go about your issue is to validate (or try to) your current system

 

Visually clean for a dry clean is fine-as long as there are not any allergens you need to control

 

Carryover should be negligible if the dry clean is done properly and thoroughly, so you should not have a labelling issue (allergens not withstanding).   For recall purposes, you may want to include a 1/2 hour production (or what you think is sufficient) from the preceding and proceeding production runs

 

Using a push through method-you could validate by contacting a local accredited lab and inquire about swabbing to verify. 

 

Then and only then, you could think about changing your process.

 

Government and GFSI both allow flexibility as no two facilities or processes are the same.  As long as you can support the decision with facts.

 

For "wet" cleaning.....you may want to have a look at dry ice for your facility. Wet cleaning in a dry powder environment could lead to the introduction of salmonella if the equipment is not 100% dry pre production

Edited by Scampi, 19 February 2021 - 02:15 PM.

[Jon19]

Thank you very much Scampi!

 

This leads me to a few follow-up questions.

 

- Would you be able to elaborate regarding a level that may be considered "negligible"? In some conversations (not from regulatory / certifier) I've heard of numbers like 1% carryover as being generally acceptable. Does that seem reasonable? Higher, lower?

 

- In addition to dry cleans, from what I gather "scrape-downs" or "brush-downs" seem fairly common practice in powder processing industry and requested by some of our customers to minimize costs of cleaning and help with efficiency (much less downtime b/c of our wet cleaning process). From what has been requested, the level of clean is not down to a visibly clean surface, rather there could be visible material left on the surface. In some cases it sounds like it could be considerable, and only consideration seems to be functional effect and not labeling. Curious to get your input on this as it seems the level does not fit with visibly clean.

 

- For dry cleaning, would you be able to suggest what is typical for cleaning the outside of equipment, floors, walls, ceilings, etc when shifting from one product to the next? Issue I see would be reducing likelihood of cross contamination through airflow, transfer from surface to surface by employees, etc. We've gone with wet washing because it is effective for thorough surface cleaning. I'm concerned that people may get frustrated with tediousness that dry-cleaning may require in larger, multi-level structures such as ours which would result in areas not being fully cleaned and/or take a long time to get done if looking for visibly clean everywhere / all surfaces.

 

- Lastly, for Swabbing is that referring to ATP, allergens, or other swab testing?

[Scampi]

I think you could safely carryover up to 5%, as long as it's effectively captured in a mock recall.............if not some rethinking may need to occur

https://www.qualitya...ing-sanitation/   this link is probably super helpful to you to answer a lot of your questions

 

 

And yes, your folks are going to get frustrated.............the only way around that is to improve the operational ventilation so that powder dust is evacuated from the space before it can land  (you can get there but there is a significant $$$ investment)

 

If you can isolate allergens to 1 day/week with a full clean after (say Fridays)    the rest of the week you should be able to simply clean the actual food contact surfaces........just a thought

 

 

The swabbing would be specific to an ingredient (say 1 blend has protein.......following blend does not)  and/or allergen swabs to validate the push through