9 replies to this topic

[MDaleDDF]

Do any of you guys path test incoming raw ingredients?  

We just had an internal audit.   I've been testing random raw ingredients that we receive, quarterly, for the last 12 years.   My last internal auditor said:   Why are you doing this?   They come with a COA and have already been tested.   You've never had a positive result.   Even if you did, what do you think the vendor would do?   They're going to say 'we already tested it, it's fine, you must've corrupted the sample'.....

 

All this actually makes sense to me, and I think I'm going to do a little write up and close this testing out in the future.  

Any thoughts or inputs guys?

Thanks.

[olenazh]

You're going to do right thing: it was waste of time and money. I've personally never heard of this path test. If my yogurts were through additional testing after they left the facility, and tests were positive - I would say the same "My products were tested prior to leaving the facility, tests came negative - so, it's your fault YOUR samples came back positive!"

[MDaleDDF]

aight, cool.   I'm gonna do a little write up and bury this chapter in my path book then.   Thanks O!

[G M]

It might be worth doing on a low frequency as a form of supplier auditing, but as a regular activity on all incoming lots, no way.  Perhaps in a trial/sample with a new vendor.

[Charles.C]

Do any of you guys path test incoming raw ingredients?  

We just had an internal audit.   I've been testing random raw ingredients that we receive, quarterly, for the last 12 years.   My last internal auditor said:   Why are you doing this?   They come with a COA and have already been tested.   You've never had a positive result.   Even if you did, what do you think the vendor would do?   They're going to say 'we already tested it, it's fine, you must've corrupted the sample'.....

 

All this actually makes sense to me, and I think I'm going to do a little write up and close this testing out in the future.  

Any thoughts or inputs guys?

Thanks.

Hi MDale,

 

Specific information on tested entity is lacking.

 

IMHO yr last internal auditor needs to be retrained unless yr unknown produce is guaranteed  BCPA  pristine and possibly totally derived from one vendor.

 

There are various demonstrations on this Forum that sometimes, COAs are representative of some particular exercise rather than from actual continuing Production.

 

Nonetheless, I appreciate that SQF (if such is applicable) is notoriously trusting where COAs are concerned.

 

Ironically, HACCP is supposed to enable the near elimination of testing of the Finished  product.

 

Cost-Cutting Environment ?

[Bo16]

This is where risk assessment comes in.  We test EVERY incoming lot of product for pathogens.  EVERY lot, and even the same manufactures lot if it is shipped and delivered with a different PO or on a different day.  We would never accept a product that fails our testing, and we make that very clear in our purchase agreements.  We purchase with the expectation that OUR testing is the acceptance criteria.  We also sample incoming in a controlled atmosphere room.  You can purchase small sampling hoods that are free standing and do not require ducting if you do not want the expense of a room.  

 

In over 20 years of testing we have suppliers that have never had any issues and some that have.  We have talked to suppliers when non-pathogenic testing is creeping up even though it is way below specifications or if we recovered an incidental organism the is not a food safety concern.  Communication has always been welcomed and usually they respond with a thank you after they find a glitch in their GMP monitoring / sanitation program.  

 

Our product last for years, has very low risk of being contaminated, but contamination would effect hundreds or thousands of kilos of finished goods over multitude of finished product types. 

 

So our allowable risk is extremely low.

[Ryan M.]

Ask yourself two questions:

 

1.  What is the purpose?

2.  What will you do if you encounter a positive result?

[Charles.C]

This is where risk assessment comes in.  We test EVERY incoming lot of product for pathogens.  EVERY lot, and even the same manufactures lot if it is shipped and delivered with a different PO or on a different day.  We would never accept a product that fails our testing, and we make that very clear in our purchase agreements.  We purchase with the expectation that OUR testing is the acceptance criteria.  We also sample incoming in a controlled atmosphere room.  You can purchase small sampling hoods that are free standing and do not require ducting if you do not want the expense of a room.  

 

In over 20 years of testing we have suppliers that have never had any issues and some that have.  We have talked to suppliers when non-pathogenic testing is creeping up even though it is way below specifications or if we recovered an incidental organism the is not a food safety concern.  Communication has always been welcomed and usually they respond with a thank you after they find a glitch in their GMP monitoring / sanitation program.  

 

Our product last for years, has very low risk of being contaminated, but contamination would effect hundreds or thousands of kilos of finished goods over multitude of finished product types. 

 

So our allowable risk is extremely low.

Hi Bo,

 

I don't disagree your Policy but IMEX it is logistically, totally, impossible to test an incoming lot sitting at one's doorstep for "Pathogens" in real time. How do you do it ?

[Bo16]

True, we cannot test for pathogens in real time, we have a hold / release program for each lot.  As for what we would do with a positive result, evaluate the OOS according to protocol for pathogen testing and sampling, if this is a food safety concern and a commercial lot where the vendor is required to control the microbial hazard, then we would notify the supplier and report it to the FDA.  Of course if this is a product where we are controlling the microbial hazard we would be verifying the Preventive Control and testing after processing and that would be a different scenario for control and CAPA (still as per protocol) since it would not be a commercial lot yet.

 

If your product is low hazard, you have enough controls in place along your supply chain and in-house, then your risk is low and maybe you do not have to test every lot as a verification step.  If micro does not grow in your product (the water activity or pH is low) and is not considered a hazard in your HACCP/food safety plan you may not need testing for verification purposes and a vendor COA will suffice.  

[Charles.C]

True, we cannot test for pathogens in real time, we have a hold / release program for each lot.  As for what we would do with a positive result, evaluate the OOS according to protocol for pathogen testing and sampling, if this is a food safety concern and a commercial lot where the vendor is required to control the microbial hazard, then we would notify the supplier and report it to the FDA.  Of course if this is a product where we are controlling the microbial hazard we would be verifying the Preventive Control and testing after processing and that would be a different scenario for control and CAPA (still as per protocol) since it would not be a commercial lot yet.

 

If your product is low hazard, you have enough controls in place along your supply chain and in-house, then your risk is low and maybe you do not have to test every lot as a verification step.  If micro does not grow in your product (the water activity or pH is low) and is not considered a hazard in your HACCP/food safety plan you may not need testing for verification purposes and a vendor COA will suffice.  

Hi Bo,

 

Thks for comments.

You are fortunate to be able to hold product for several days. My experience (seafood) is almost entirely with perishables. Some sampling/testing for indicators/pathogens is carried out on a risk-based prioritization but any corrective/punitive actions are unavoidably retrospective.