8 replies to this topic

[acarver]

Anyone else a coffee roaster with SQF? We are a small roaster/tea blender working on SQF Certification. My consultant gave me instructions for our EMP, when I called lab with his suggestions they said they would not go that route, but did not want to advise because I have a consultant. Now I am stuck in the middle. I've looked at info here, but most of it is for larger operations that are not at all similar. I am stuck and need a push in the right direction.

 

TIA!

[kfromNE]

What was the consultants recommendations? What was the labs recommendations? What country are you located in?

When you say small - what does that mean?

[SQFconsultant]

We are not coffee roasters but we do have clients that are.

I am assuming that your consultant and you first determined that an EMP was needed?

[acarver]

Small business, meaning less than 12 employees: office, warehouse, production, management. 100,000 lbs, month production each coffee and tea/month, running 4 lines of each (more lines available for coffee but consistently run 4 lines). SQF requires EMP. 

 

Consultant suggested 10 swabs for EB in production from floor (literally off floor) 2X a year. Note that this also makes me hesitant because any positive will require retest to determine what is causing the positive. He says testing for Salmonella is asking for trouble from the start. (Also water testing from cleaning and hand wash sinks, but this makes sense.)

 

We do random labs now on products, including salmonella on the list, and (thankfully) have never had a positive.

 

The only water used in production is to quench roast. No compressed air is used.

 

Thanks.

[OrRedFood]

The Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food - Appendix 1 Tables (fda.gov) tells you what the organisms of concern are for your food product.  Roasted Coffee Beans is on page 20, and there are no micro risks listed.  You do mention tea, which does have Salmonella listed as a organism of concern, I would question your consultant on that.   Eb is a good indicator of employee hygiene and footwear cleanliness.  Do your employees have plant-only footwear, or do they wear their own shoes?

 

I would not worry about having to reswab if you find a positive, it's a lot better that testing your product and getting a positive!  Environmental swabbing is always done on areas underneath your food product contact zone, such as drains, floors, under production tables, employees shoes, standing water, etc.  Not food contact zones.  

 

Finding the source is important to keep it out of your product and just makes your food safety plan stronger.  Auditors expect you to find problems, and to correct them. 

 

Put together a plan for investigating any environmental positives, recleaning, and swabbing to find the source. Document everything.  Review your sanitation procedures in the area that is positive, reclean, and reswab the same are plus some areas surrounding it to pinpoint the source.  Document changes to your sanitation SOPs that you update to prevent further contamination.  

Edited by OrRedFood, 29 April 2022 - 05:11 PM.

[acarver]

Thanks, this is very helpful and probably the push I need to get me going on this standard. I have a better understanding of the goal/purpose of the testing; that makes all the difference!

[Charles.C]

Thanks, this is very helpful and probably the push I need to get me going on this standard. I have a better understanding of the goal/purpose of the testing; that makes all the difference!

Hi acarver,

 

EMPG is ultimately based on your risk assessment of your Process, eg via zoning.

 

 

The FDA (eg link in Post 5) draft Process opinion may be contentious. For example see this previous thread, especially posts (11 - 14) -

 

https://www.ifsqn.co...542#entry126542

 

Eb (Post 4) (I assume = Enterobacteriaceae) is a Quantitative indicator with limits, not afaik a positive/negative one like zero-tolerant Salmonella.

[acarver]

Hi acarver,

 

EMPG is ultimately based on your risk assessment of your Process, eg via zoning.

 

 

The FDA (eg link in Post 5) draft Process opinion may be contentious. For example see this previous thread, especially posts (11 - 14) -

 

https://www.ifsqn.co...542#entry126542

 

Eb (Post 4) (I assume = Enterobacteriaceae) is a Quantitative indicator with limits, not afaik a positive/negative one like zero-tolerant Salmonella.

I run random product testing for Salmonella (among other things) monthly and have for years. I'm clear that the EMP is for my situation.

[Charles.C]

I run random product testing for Salmonella (among other things) monthly and have for years. I'm clear that the EMP is for my situation.

 

Hi acarver,

 

Re ^^^(red) - Yr Posts 1, 4 seemed to intimate otherwise.

 

IMEX End-product testing is typically HACCP Verification. Not so much EMPG Validation.

 

Regardless, Good Luck with yr forthcoming SQF audit !.

 

PS - It's a Subjective Topic but FWIW -

 

 EMPG Decision Tree.png   497.89KB   2 downloads

Edited by Charles.C, 02 May 2022 - 03:50 AM.
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