11 replies to this topic

[KingaZ]

Hi All,

We have many supplier who use irrigation water for their fresh produce crops. Some of the irrigation water undergoes mild chlorination at the point of abstraction from reservoir. The chemical level is low 1 ppm and it does not remove microbiological load but reduces it if higher. This can not be controlled in a way that you always guarantee reduction to certain cfu/ml eg. <100 cfu/100ml for e.coli because you do not know your starting point (it could be anything from 0 to a lot as water is abstracted from river to the reservoir. You also can not use higher amount of chlorine dioxide / sodium hypo. As if it will scorch (quality) your fresh produce and you’ll produce nothing.

Therefore questions is - should this be a CCP to control microbiological hazard?
This is fresh produce i.e. leafy greens red chard, spinach.
Hazard identified is water contamination with pathogens etc.
chlorination MAY remove the hazard or May reduce it to potentially acceptable level. However even with validation of the chlorination water being successful you can not predict water contamination at later date (river abstraction).
Irrigation is only used if needed during dry/hot periods so it’s not a permanent process step.
Even with chlorination reducing micro load in the water this will still not constitute fresh produce to be safe to eat as further steps are required I.e. wash before use by end consumer.
Product (fresh produce) is not designed to be ready to eat.

One of our customers requests this process to be a CCP and just need to brainstorm with you.

Please share your thoughts.

[Charles.C]

Hi All,

We have many supplier who use irrigation water for their fresh produce crops. Some of the irrigation water undergoes mild chlorination at the point of abstraction from reservoir. The chemical level is low 1 ppm and it does not remove microbiological load but reduces it if higher. This can not be controlled in a way that you always guarantee reduction to certain cfu/ml eg. <100 cfu/100ml for e.coli because you do not know your starting point (it could be anything from 0 to a lot as water is abstracted from river to the reservoir. You also can not use higher amount of chlorine dioxide / sodium hypo. As if it will scorch (quality) your fresh produce and you’ll produce nothing.

Therefore questions is - should this be a CCP to control microbiological hazard?
This is fresh produce i.e. leafy greens red chard, spinach.
Hazard identified is water contamination with pathogens etc.
chlorination MAY remove the hazard or May reduce it to potentially acceptable level. However even with validation of the chlorination water being successful you can not predict water contamination at later date (river abstraction).
Irrigation is only used if needed during dry/hot periods so it’s not a permanent process step.
Even with chlorination reducing micro load in the water this will still not constitute fresh produce to be safe to eat as further steps are required I.e. wash before use by end consumer.
Product (fresh produce) is not designed to be ready to eat.

One of our customers requests this process to be a CCP and just need to brainstorm with you.

Please share your thoughts.

Hi KZ,

 

Which Standard ?

[KingaZ]

Hi

Supplier work to either Global Gap or Red tractor. There is no specific Code of practice that they need to work to.
Thank you

[Scampi]

A) will the produce be flumed post harvest or is it field pack and ship

 

B) what produce type is it (generally speaking)

[KingaZ]

Hello

A) it can be packed after harvest into bags ( no post-harvest treatment) and sold as “wash before use salad mix”
B) baby leaves - spinach, red chard, baby iceberg, mizuna, wild rocket,

It can also be sold as raw material in crates for further processing elsewhere.

Regards

[Faith S]

Hi ,

 

I would say its a PRP not a CCP 

[Charles.C]

Hi All,

We have many supplier who use irrigation water for their fresh produce crops. Some of the irrigation water undergoes mild chlorination at the point of abstraction from reservoir. The chemical level is low 1 ppm and it does not remove microbiological load but reduces it if higher. This can not be controlled in a way that you always guarantee reduction to certain cfu/ml eg. <100 cfu/100ml for e.coli because you do not know your starting point (it could be anything from 0 to a lot as water is abstracted from river to the reservoir. You also can not use higher amount of chlorine dioxide / sodium hypo. As if it will scorch (quality) your fresh produce and you’ll produce nothing.

Therefore questions is - should this be a CCP to control microbiological hazard?
This is fresh produce i.e. leafy greens red chard, spinach.
Hazard identified is water contamination with pathogens etc.
chlorination MAY remove the hazard or May reduce it to potentially acceptable level. However even with validation of the chlorination water being successful you can not predict water contamination at later date (river abstraction).
Irrigation is only used if needed during dry/hot periods so it’s not a permanent process step.
Even with chlorination reducing micro load in the water this will still not constitute fresh produce to be safe to eat as further steps are required I.e. wash before use by end consumer.
Product (fresh produce) is not designed to be ready to eat.

One of our customers requests this process to be a CCP and just need to brainstorm with you.

Please share your thoughts.

Hi KingaZ,

 

Pre-harvest processing not my area of expertise but IIRC Global Gap offer some example hazard analyses for typical systems within their scope. Also attached or linked "somewhere" on this Forum I think. Maybe try a search.

(I seem to recall that their format/style looked rather "old-fashioned").

[Scampi]

I would caution your choice of determining leafy greens as non RTE

 

Washing of leafy greens is by no means a kill step, and most of the items you mentioned is going to be cooked typically

 

I firmly believe you should be treating them as RTE and as such, your water source needs to be potable, i/e no detectable e coli levels

 

FYI----there have been many many people sickened by consuming leafy greens that were irrigated using canal/reservoir (read run-off) water which is always contaminated but to varying degrees.  IMHO the water source needs to be a CCP

 

https://www.fda.gov/...tec-action-plan

 

https://www.fda.gov/...reak-salmonella

 

https://www.foodsafe...g/leafy-greens/

 

To me the logic or science just isn't there to support the RTC position

[JensV]

Hi KingaZ

 

I agree with Scampi.

 

This product may be not designed as RTE, but consumers will use it from time to time as RTE. From my experience, even if it is explicitly mentioned on the label as a precaution, this may cause problems and you may not get away with it.

 

The water will be a CCP as there are probably no successive process steps to reduce the (potential) microbiological load.

 

But as I understand it, the quality (in terms of food safety) of the irrigation water cannot be sufficiently guaranteed, also not by e.g. chlorination (what would have been the control parameter). Therefore it seems inadvisable to use irrigation water.

Edited by JensV, 12 July 2022 - 02:41 PM.

[maggiemay]

The California LGMA is great resource which might be helpful in answering your question on irrigation:   

 

https://lgma.ca.gov/...ct/water-use/p2

[Tony-C]

Hi KingaZ,

 

I would tend to agree with comments made by Scampi and JensV, although I believe people will wash their salads, you cannot suddenly decide that they are not RTE.

 

Clearly there is potential for contaminated water to contaminate your products, there is historical evidence (there have been many outbreaks of produce-associated illness) and so this needs to be addressed.

 

We could debate whether it is a CCP or PRP but ultimately the quality of irrigation water needs to be controlled, whether it is by chlorination or by another method or a combination of the two.

 

You may find some useful information in this article: Microbiological Reduction Strategies of Irrigation Water for Fresh Produce

 

Kind regards,

Tony

[Charles.C]

Hi KingaZ,

 

Purely speculative (ie "sharing thoughts") -

 

(1) The initial essence of HACCP is to determine whether a hazard is Significant or not. In yr case, this appears to demand a qualitative/quantitative evaluation of the risk due water supply and its consistency. (Contrary to Best Practice ?).

 

(2) From a purely Global Gap (or whomsoever is applicable) perspective it is necessary to determine their HACCP "Policy" regarding the designation of PRPs/CCPs (many older interpretations of Codex haccp semi-automatically set "raw material receiving" related stages as CCPs for a variety of "hazards" whereas many later presentations/current tend to utilize PRPs).

 

(3) As formally espoused by iso22000, process hazards associated with a given process X may be regarded as non-significant if a subsequent Process Y can be validated as "eliminating" the previously associated risk. (this typically [micro.] also includes the final consumer, eg "Cooking" is often conventionally > Yes, "Washing" IMO probably > No).