8 replies to this topic

[Khazard]

Greetings all, I hope you guys can help/offer some advice here.

 

I have worked for a company that processes smoked fish and each year the EHO shows up and raises new issues with my HACCP plans.

 

I have worked within the Food industry for years and have implemented and achieved BRC AA on a few sites with no issues, however this EHO is driving me nutts.

 

I have conducted a risk assessment and having identified Listeria as being hazard i have created a CCP for a listercidal kill step during the cooking phase. and have undertaken many shelf life tests from day 0 to day 30 (declared shelf life 21 days) and have never had any issues except for the occasional yest detected towards the end of life.

 

The EHO has said that i need to determine the controlling factors for listeria. against the EC regs with regards to Absent from...

 

As far as im concerned i have in that i have

1) identified and have procedures for cleaning and sanitation and all the other PRP's which refer to pathogens of concern.

2) Included within my risk assessments Pathogens of concern and referenced said PRP's at relevant process steps and the kill step as a CCP with all corrective actions etc..

3) i have validated the the controls 

4) I  am currently verification the controls through taking micro swabs and product sampling.

 

I believe i have covered everything which is why im stumped. 

Personally feel she has a bee in her bonnet with our site... shes been many times before and had no issues relating to this. and now suddenly its an issue.

 

Whats more is im asked for documents, which i give and then get quized on info thats clearly in them showing she has not even read them.

 

Any help appreciated.

 

 

 

 

[Charles.C]

Greetings all, I hope you guys can help/offer some advice here.

 

I have worked for a company that processes smoked fish and each year the EHO shows up and raises new issues with my HACCP plans.

 

I have worked within the Food industry for years and have implemented and achieved BRC AA on a few sites with no issues, however this EHO is driving me nutts.

 

I have conducted a risk assessment and having identified Listeria as being hazard i have created a CCP for a listercidal kill step during the cooking phase. and have undertaken many shelf life tests from day 0 to day 30 (declared shelf life 21 days) and have never had any issues except for the occasional yest detected towards the end of life.

 

The EHO has said that i need to determine the controlling factors for listeria. against the EC regs with regards to Absent from...

 

As far as im concerned i have in that i have

1) identified and have procedures for cleaning and sanitation and all the other PRP's which refer to pathogens of concern.

2) Included within my risk assessments Pathogens of concern and referenced said PRP's at relevant process steps and the kill step as a CCP with all corrective actions etc..

3) i have validated the the controls 

4) I  am currently verification the controls through taking micro swabs and product sampling.

 

I believe i have covered everything which is why im stumped. 

Personally feel she has a bee in her bonnet with our site... shes been many times before and had no issues relating to this. and now suddenly its an issue.

 

Whats more is im asked for documents, which i give and then get quized on info thats clearly in them showing she has not even read them.

 

Any help appreciated.

Hi Khazard,

 

I presume this is a UK - related query but consumer is in EC.

 

I presume your/EC  "Listeria" = L.monocytogenes.

 

A few queries -

 

(1) is the RTE product chilled, Vac/MAP packed ?

 

(2) what do the EC Regs specifically require ? (I anticipate for L.mono, nMc = 5/not detected/0)

 

(3)  why does the EHO specifically consider yr current presentation/data inadequate ? eg Have you validated that process  cook step  achieves sufficient lethality/microbial reduction ?

[Khazard]

Hi Charles, thank you for your response...

Yes I'm uk based the consumer is also UK based not ec.
The product is rte cooked.
It is vac packed in 1 format, hence aw and wps controlled as a requirement
Yes for listeria hence ccp cooking kill step, regs requiring absent in 25g sample
Validation is done showing consistent controll of process step and verified with samples over 2 Yes

I'm currently awaiting ejo report but the was she explained it to me was confusing maybe language barrier, but was talking about listing controlling factors and referring to potential contamination after cooking.
I need to get more info from them when I get the chance.

[Charles.C]

Hi Charles, thank you for your response...

Yes I'm uk based the consumer is also UK based not ec.
The product is rte cooked.
It is vac packed in 1 format, hence aw and wps controlled as a requirement
Yes for listeria hence ccp cooking kill step, regs requiring absent in 25g sample
Validation is done showing consistent controll of process step and verified with samples over 2 Yes

I'm currently awaiting ejo report but the was she explained it to me was confusing maybe language barrier, but was talking about listing controlling factors and referring to potential contamination after cooking.
I need to get more info from them when I get the chance.

Hi Khazard,

 

Thks info.

I assume all cases are chilled storage.

I don't quite understand why the auditor would mention EC (post Brexit) and anyway yr product totally UK driven. ("Living in the Past" )

From haccp POV, L.mono will prioritise in non-vac. cases. C.botulinum will prioritise in vac.pack although L.mono also to be considered.

These are both tricky product categories especially since yr shelf life is "extended"

 

My guess the EHO studying yr plans/data at length.

 

Can find some related UK(mainly)/US discussion at posts/threads linked below and files attached at end this post -

 

https://www.ifsqn.co...nt/#entry161775

https://www.ifsqn.co...um/#entry134554

 

 Non-proteolytic-Clostridium-botulinum-shelf-life-guidance-FINAL-1st-Ed-9-7-18-1.pdf   430.1KB   12 downloads

 Decision Tree,chilled,L.monocytogenes.pdf   591.8KB   11 downloads

(cf your mention of absence L.mono although EC has a slightly different presentation IIRC)

[Khazard]

So i now have the report, 

 

i need to present documented evidence how of how appropriate validation is achieved specifically with regards to c.bot for vac pack products with shelf life greater than 10 days.

This will include controlling factors which will be reflected in corresponding CCP's which would then be monitored.

 

The controlling factor to achieve wps and aw requirements as per chileld vac pack regs is undertaken by ensuring brining process is sufficient to achieve those parameters. Brine strength and water lvl is Static, Brine time is the ccp and is monitored on paperwork. Time of brine is greater than required on paperwork which is the CCP. Evidence of the controlling factor working is based on documentation by the FSA and researching bodies that inform of this factor being sufficient.

 

I can only assume my validation study document is not ideal and perhaps need to create a new format and to include more information or presented better.

 

what are your thoughts?

[Charles.C]

So i now have the report, 

 

i need to present documented evidence how of how appropriate validation is achieved specifically with regards to c.bot for vac pack products with shelf life greater than 10 days.

This will include controlling factors which will be reflected in corresponding CCP's which would then be monitored.

 

The controlling factor to achieve wps and aw requirements as per chileld vac pack regs is undertaken by ensuring brining process is sufficient to achieve those parameters. Brine strength and water lvl is Static, Brine time is the ccp and is monitored on paperwork. Time of brine is greater than required on paperwork which is the CCP. Evidence of the controlling factor working is based on documentation by the FSA and researching bodies that inform of this factor being sufficient.

 

I can only assume my validation study document is not ideal and perhaps need to create a new format and to include more information or presented better.

 

what are your thoughts?

Hi Khazard,

 

I guess you need to ask BRC  EHO why the Validation already submitted was not sufficient (which I would have expected them to have noted in the audit or report).

Edited by Charles.C, 12 April 2022 - 11:51 AM.
corrected

[Khazard]

was EHO not BRC, and word for word is what i wrote. its baffling me and trying to get a response and waiting a week for replies is annoying and no phone contact as there always on site somewhere.

[Scampi]

Have you had a lab perform a thorough analysis of your product?  You said you had a shelf life study--how many samples in the study, and was it repeated?  Or did you do a one and done?

[Charles.C]

was EHO not BRC, and word for word is what i wrote. its baffling me and trying to get a response and waiting a week for replies is annoying and no phone contact as there always on site somewhere.

Is it possible to upload the Validation Section here for "comments" ?