Biological Hazards Question
This might be limited to a certain number of ppl on here but i wanted to hear your thoughts.
Are ya'll listing any biological hazards for raw materials that are mustard condiments we use in our finished product? Grainy Dijon mustard, Mustard bran, mustard paste, etc>
Previously we had not, but that FDA guidance chart shows some potential pathogens to consider on some mustards condiments we purchase to go in our products. They list E.Coli, Salmonella, and Listeria. I don 't really feel those are legit but I dont' want to leave them out and get hit on it during Prev. Controls audit either.
I wanted to see what ya'll have before I add them to mine. Thoughts?
Thanks everyone
Can you expound on why you think they're not legit?
Do you have the ability to get a COA from your ingredient suppliers?
I think the potential is absolutely there, even though it is minor. We've begun to mirror the FDA tables where they apply to our business, then review those ingredients to see whether they've been involved in recalls as part of our risk assessment. We also require COA's showing micro from all of our non-fresh ingredient vendors for things such as condiments.
I'm assuming everyone in this thread is referring to my attached file? Auditors that I have spoke to have also referenced this document as a great starting point when assessing the risks present in your raw materials. At the very least, I would recommend addressing these risks through some kind of supplier qualification that would include CoA review and periodic testing of the raw material.
Attached Files
Mustard ingredients that have NOT undergone a kill step will naturally have a biological (and chemical) risk
These are raw agricultural commodities and as such, yep e coli will (not may) be present
This is also a great resource https://active.inspe...arece.aspx?i=11 it's a reference database of hazards and it's been around for more than a decade
It lists ingredients and processing steps (I guess the FDA finally caught up lol)
Mustard ingredients that have NOT undergone a kill step will naturally have a biological (and chemical) risk
These are raw agricultural commodities and as such, yep e coli will (not may) be present
This is also a great resource https://active.inspe...arece.aspx?i=11 it's a reference database of hazards and it's been around for more than a decade
It lists ingredients and processing steps (I guess the FDA finally caught up lol)
JFI - the Draft Guidance lists Pathogenic E,coli, not Generic E.coli.
"Listeria", per se, is not a pathogen and is also not listed in the Draft Guidance as such. (L.monocytogenes is listed).
In our ingredient analysis for yellow mustard we list both pathogenic listeria and salmonella spp. The supplier uses a max pH of 3.6 as a control. The supplier provided us with their flow chart. We then receive a COA with the pH. It was mentioned to us that it is best to reference FDA Appendix 1, if you do not use what there guidelines state, then you must provide justification.
For the purpose of a preventative control plan, there is a risk. If the product is not properly processed etc, the raw material could be a food safety risk.
In your case, the supplier controls the risk. It would be a good candidate for a supply chain preventative control.
That is how I would address it. Others may have a different opinion.
i just noticed this was an old thread.