6 replies to this topic

[oxkjs1]

I have really enjoyed this forum and appreciate the advice and access that it provides to newbies like me.  I am posting my first question with hopes that someone has experience for our issue and can give some advice.

 

We are a petrochemical company working towards FSSC 22000-Q certification for application to animal feed ingredients.   I have a question about clause 4.6.3-03 in ISO 220006-2 which states:

 

A representative sample of each incoming material for inclusion in a lot or batch shall be maintained for an appropriate period of time.

 

We have several ingredients which presents serious personnel safety issues related to sampling and handling since they are not stable at room temperature and must be maintained under pressure at all times.   Based on decades of experience, the ingredient is not a significant source of feed safety hazards as it is essentially be completely reacted in the reactor (petrochemical manufacturing process) and impurities are removed in downstream purification processes.

 

What other options can meet this requirement rather than retaining a sample?  My idea is to document why sampling/retention is not practical / safe and to rely on traceability to the supplier's analytical data for the shipment (also a petrochemical bulk product).    Another option is to use a reactor product sample as a surrogate for the raw material.

 

What are thoughts from those of you experienced with ISO 22000 certification and FSSC 22000?

 

Thanks!

Newbie

[Scampi]

lemme get this straight

 

you're a petrochem facility who wants to manufacture an ingredient(s) for animal feed, but some of the animal feed are not "stable" so you don't want to hold a retain?

 

So if said ingredient isn't stable enough for a retain, how is it stable enough to add to feed?

 

Are you a petro company or a feed company?          I apologize for my commodity ignorance on this, i'm having a hard time connecting the dots not sure how an ingredient can pose a H&S risk in handling and an approved additive for feed

[oxkjs1]

Thanks for your question.   I will try to clarify the situation.  Our raw materials are petrochemical derived products that we convert, through chemical reaction, into a completely different petrochemical product that may be used as an ingredient in animal feed by animal feed manufacturers. 

 

Our raw material is unstable so I don't want to sample it or keep a retain of it.

Edited by oxkjs1, 05 July 2022 - 05:12 PM.

[pHruit]

A representative sample of each incoming material for inclusion in a lot or batch shall be maintained for an appropriate period of time.

I'm not experienced with ISO22k, so please ignore my comments if not helpful, but the clause as written in your post doesn't appear to specify that *you* need to retain the sample, or that you need to draw the sample yourselves - only that a sample is kept and is representative.

Might it be possible to satisfy this by either asking your suppliers to ship a small batch sample with your delivery (they might be more likely to have facilities to prepare small sealed batch samples safely?), or simply obtaining confirmation that they retain a sample and will do so for the "appropriate" period of time, e.g. shelf life of your products plus a margin of error?

 

 

So if said ingredient isn't stable enough for a retain, how is it stable enough to add to feed?

 

I can see how this could be a genuine problem in the more chemical-based side of the industry, and indeed I'd have this same issue if BRC mandated the same raw material sampling requirement, despite very definitely making food products for humans. Even for some "normal" food ingredients this could be a challenge e.g.: CO2 used in carbonated drinks would be a headache to sample and store safely, various essential oils are potentially corrosive, flammable etc and absolutely are a safety hazard during handling, and that's before you get to some of the volatile aromatic chemical substances used in flavourings.

[oxkjs1]

pHruit.  Yes, you seem to grasp my concerns exactly.  Our supplier would not want to ship a sample or keep retains due to all the same safety concerns.  I would think that a certification body cannot withhold certification for this one clause based on a safety hazard conflict.  Especially when a retain would not really be necessary to ensure food safety of our final product or prevent the ability to do proper traceability.   Our final product is a homogeneous liquid that can be fully analyzed for virtually any component of concern.  We determine product purity primarily using Gas Chromatography. 

[PQEdwards]

A similar situation we have have experience of is a raw material (96% Sulphuric acid) which is hazardous to sample and undesirable to store because of the hazardous nature of the material. I know the FAMI-QS standard for speciality feed ingredients (Clause 8.6.2) has a caviat about "health and safety risks must be taken into consideration". There no such explicit statement in ISO/TS22002-6(2016) clause 4.6.3 but the word "where appropriate" is used. I suggest you document why it is not appropropriate to retain samples of the this particular raw material, which may include a safety element and other mitigation.

[oxkjs1]

A similar situation we have have experience of is a raw material (96% Sulphuric acid) which is hazardous to sample and undesirable to store because of the hazardous nature of the material. I know the FAMI-QS standard for speciality feed ingredients (Clause 8.6.2) has a caviat about "health and safety risks must be taken into consideration". There no such explicit statement in ISO/TS22002-6(2016) clause 4.6.3 but the word "where appropriate" is used. I suggest you document why it is not appropropriate to retain samples of the this particular raw material, which may include a safety element and other mitigation.

 

Thanks for sharing your situation.  This gives me more confidence that every effort should be made to sample / keep a retain of your raw material for traceability and for food safety.  However, where this is not practical due to legitimate safety hazards, we will look for alternative ways to review, approve and trace the use of the raw material.

 

Kind Regards!