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JoaquinBarbero

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Posted 09 November 2022 - 10:02 AM

Good day All,

 

Many thanks for giving me the possibility to participate in this forum!

 

My name is Joaquin and I'm a Quality Officer in the brewing Industry.

 

Next month I have the challenge of validating the CCP on Site, and I have two questions.

 

 

1) One CCP is related to glass inclusion. When the glass breakage happens in a specific area an auto flush system will be activated and clean the area.

 

The Critical control is the Pressure of the water flushing the area but the validation is an inspection of the site after the glass breakage. If the area is clean without glass the CCP can be validated (This validation is also a policy that the company needs to follow). My question is:  How would you simulate that glass breakage? I've heard some collapsable bottles are sometimes used for this validation. Does anyone know where I can find them? 

 

 

2) Another CCP is related to water contamination with glycol, for preventing that the control is the Interlock safety system that would avoid the inclusion of glycol in the water used as raw material. I was thinking of a validation to check the PH of the water after triggering that interlocking system, but I'm not sure. Is there any other way to detect Glycol in water doing analysis?

 

Many thanks!

 

Joaquin 



Marloes

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Posted 09 November 2022 - 03:07 PM

Hi Joaquin,

 

Welcome to the forum!

Can you contact the suppliers of your auto flush system and the glycol?
Perhaps they have specific testing methods.
Especially for the auto flush system there should be some testing method. I would imagine similar to metal detector sticks. I would recommend to find a testing method that does not introduce dangers in your production process (e.g. actual glass). 
I have also seen glycol testing kits, but I am not sure if they can be used for food industry or if they are sensitive enough for your needs.



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Charles.C

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Posted 10 November 2022 - 08:36 AM

Good day All,

 

Many thanks for giving me the possibility to participate in this forum!

 

My name is Joaquin and I'm a Quality Officer in the brewing Industry.

 

Next month I have the challenge of validating the CCP on Site, and I have two questions.

 

 

1) One CCP is related to glass inclusion. When the glass breakage happens in a specific area an auto flush system will be activated and clean the area.

 

The Critical control is the Pressure of the water flushing the area but the validation is an inspection of the site after the glass breakage. If the area is clean without glass the CCP can be validated (This validation is also a policy that the company needs to follow). My question is:  How would you simulate that glass breakage? I've heard some collapsable bottles are sometimes used for this validation. Does anyone know where I can find them? 

 

 

2) Another CCP is related to water contamination with glycol, for preventing that the control is the Interlock safety system that would avoid the inclusion of glycol in the water used as raw material. I was thinking of a validation to check the PH of the water after triggering that interlocking system, but I'm not sure. Is there any other way to detect Glycol in water doing analysis?

 

Many thanks!

 

Joaquin 

Hi Joaquin,

 

(1,2 ) Sounds like PRPs to me, ie (Process Flowchart unknown) as i understand not specifically related to a Process Step(s) ?


Kind Regards,

 

Charles.C


Evans X.

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Posted 10 November 2022 - 09:16 AM

Greetings Joaquin,

 

I have a few questions that need to be clarified.

 

On the 1st part of your query, the water pressure, in my opinion, isn't a control point worth treating as anything more than an oPRP and even more it can really be a PRP. The actual control point is if the system does work when it detects breakage. So your validation should be something like a metal detector. You can pass through the system, lets say every 10.000 bottles produced, bottle samples broken in various points (bottle neck, bottom, middle etc) and see if it will be activated every time.

On the 2nd part, it would be better if you specified what kind of glycol is it that you may have a problem with. Glycol strictly refers to a class of alcohols and you can have propylene glycol or ethylene glycol and so on, though I guess you mean food-grafe propylene glycol. Also, how is it possible that glycol may be mixed with the water? In my experience with 3 different breweries, it was never an issue since it is only used in the temperature regulation machinery and not directly in the product. So it falls actually in the maintenace programs etc.

 

Regards!



Joacobar

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Posted 10 November 2022 - 10:41 AM

Hi Joaquin,

 

(1,2 ) Sounds like PRPs to me, ie (Process Flowchart unknown) as i understand not specifically related to a Process Step(s) ?

Hi Charles, 

 

Thanks for replying back, Yes we reviewed the risk assessment but because the burst bottle sequence is part of a policy that the company needs to follow, is treated as a CCP. The glycol probably will be a PRP !

Many thanks again!



Joacobar

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Posted 10 November 2022 - 10:50 AM

Greetings Joaquin,

 

I have a few questions that need to be clarified.

 

On the 1st part of your query, the water pressure, in my opinion, isn't a control point worth treating as anything more than an oPRP and even more it can really be a PRP. The actual control point is if the system does work when it detects breakage. So your validation should be something like a metal detector. You can pass through the system, lets say every 10.000 bottles produced, bottle samples broken in various points (bottle neck, bottom, middle etc) and see if it will be activated every time.

On the 2nd part, it would be better if you specified what kind of glycol is it that you may have a problem with. Glycol strictly refers to a class of alcohols and you can have propylene glycol or ethylene glycol and so on, though I guess you mean food-grafe propylene glycol. Also, how is it possible that glycol may be mixed with the water? In my experience with 3 different breweries, it was never an issue since it is only used in the temperature regulation machinery and not directly in the product. So it falls actually in the maintenace programs etc.

 

Regards!

Hi Evans!

 

Yes that's a very good point, our Glycol is "Non-toxic" but not "food safe" and there is a kind of a grey area in terms of legality that I still need to have a look. On terms of the Burst Bottle sequence, We do have a detector but it is before the Rinsing/Filling step of the bottle. The Rinsing/Filling step is the place where most of the glass breakages occur, and the company does not have any kind of detector afterwards, that is the reason for the Flush system which will be activated after the breakage occurs and it's also a policy that the company needs to follow because we are part of a big group of breweries (I would love to change that CCP XD). That it's because I was thinking of simulating the breakage and seeing how effective is the Burst bottle System/Auto Flush system. Many thanks for your Answer it was really helpful! 

Cheers!



Joacobar

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Posted 10 November 2022 - 10:53 AM

Hi Joaquin,

 

Welcome to the forum!

Can you contact the suppliers of your auto flush system and the glycol?
Perhaps they have specific testing methods.
Especially for the auto flush system there should be some testing method. I would imagine similar to metal detector sticks. I would recommend to find a testing method that does not introduce dangers in your production process (e.g. actual glass). 
I have also seen glycol testing kits, but I am not sure if they can be used for food industry or if they are sensitive enough for your needs.

Hi Marloes!

 

Yes, I tried to contact them but the answers were not really accurate. 

I will probably need to review the Risk assessment again, the problem with the Burst bottle Sequence (CCP) is also a Policy that the company needs to follow because we are part of a big group of companies :(.

 

Many thanks for your answer! It was really helpful! 



Evans X.

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Posted 10 November 2022 - 11:28 AM

Hi Joacobar,

 

So in a way you do have some kind of detection during the Rinsing/Filling step, which activates the Auto Flush System (meaning it's not activated through observation from a worker). So that's what you have to validate. In the example I gave in the previous post you will pass bottle samples every 10k or 20k or 30k bottles -placing them just before the Rinsing/Filling step- to verify the system will activate and that is your CCP, leaving out the water pressure as a PRP (or oPRP at best).

In my opinion given that the glycol doesn't come in direct contact, since it passes only through the heat exchanger plates/lines, remove it from CCP and have it checked only in case there is a malfunction that may cause spillage in the water used for the product or the product itself.

Food grade propylene glycol is even sold in amazon (no endorsing attempt here!), so you won't have any problem finding for industrial scale quantities!



pHruit

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Posted 10 November 2022 - 02:22 PM

2) Another CCP is related to water contamination with glycol, for preventing that the control is the Interlock safety system that would avoid the inclusion of glycol in the water used as raw material. I was thinking of a validation to check the PH of the water after triggering that interlocking system, but I'm not sure. Is there any other way to detect Glycol in water doing analysis?

There has already been discussion above on the specifics of the glycol, so getting that confirmed / changed to food grade material covers part of it.

Whether pH could be used as part of the verification procedures is going to depend on the specifics of the glycol you end up using, as some would be in a similar range to water, and therefore wouldn't be detectable.

 

Do you have a way to measure the pressure of the glycol circuit and the product?

IMEX it's quite a common approach to run at positive pressure (i.e. pressure of the product side is higher than the pressure in the glycol side of the exchanger) and that way if there is a leak you'll get beer in your glycol, rather than glycol in your beer.

Your demonstration that cross-contamination of glycol into the product is then achieved by confirming the pressure differential is in the "right" direction (i.e. product pressure is higher than glycol pressure) at start and throughout the process.

If you don't have the equipment to do this then it should be fairly trivial to get a few gauges added to suitable points in your pipework, combined with a modification to your production forms to allow the readings to be recorded, and a modification to the work instruction/procedure to define the pressure requirement and the action to take if it isn't correct.

 

Ideally you'd perhaps also combine this with heat exchanger integrity testing as part of your maintenance schedule. Many places seem to do this annually, although I think some of the UK retailers would prefer to see it every six months.



Joacobar

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Posted 10 November 2022 - 04:00 PM

There has already been discussion above on the specifics of the glycol, so getting that confirmed / changed to food grade material covers part of it.

Whether pH could be used as part of the verification procedures is going to depend on the specifics of the glycol you end up using, as some would be in a similar range to water, and therefore wouldn't be detectable.

 

Do you have a way to measure the pressure of the glycol circuit and the product?

IMEX it's quite a common approach to run at positive pressure (i.e. pressure of the product side is higher than the pressure in the glycol side of the exchanger) and that way if there is a leak you'll get beer in your glycol, rather than glycol in your beer.

Your demonstration that cross-contamination of glycol into the product is then achieved by confirming the pressure differential is in the "right" direction (i.e. product pressure is higher than glycol pressure) at start and throughout the process.

If you don't have the equipment to do this then it should be fairly trivial to get a few gauges added to suitable points in your pipework, combined with a modification to your production forms to allow the readings to be recorded, and a modification to the work instruction/procedure to define the pressure requirement and the action to take if it isn't correct.

 

Ideally you'd perhaps also combine this with heat exchanger integrity testing as part of your maintenance schedule. Many places seem to do this annually, although I think some of the UK retailers would prefer to see it every six months.

Hello! yes we already have ways to track the pressure of each side (Beer/Glycol and Water/Glycol) and the Control is that difference you are mentioning. Knowing there are other breweries also not considerating this as a CCP probably I will create another HACCP meeting for a second Risk assessment and get rid of the CCP

 

Probably the actions will fall on the Maintenace plan (Bi-monthly check of the heat exchanger).

 

Many many thanks!





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