13 replies to this topic

[gina0509]

Hi all,

We have a very small Lupin manufacturing company. We are trying to get BRCGS certified. We are classed low risk. However, for environmental monitoring what microbes should we be testing for?

Presently, we do Ecoli, Coliforms, TPC.

Should we be considering Listeria and Salmonella? For Drains? 

We dont use any animal products. We have outsourced some of our products. They come back to us only for packing. 

 

We use UV filtered rain water. What tests should we be looking at? We are doing Heterotrophic colony @22 deg C and 36 Deg C and coliforms. What else would be required?

Please can anyone advise

Thankyou

[MOHAMMED ZAMEERUDDIN]

Hi,

For environmental monitoring you should test for E.coli, Coliforms, TPC, Salmonella.

For Water you should perform enumeration of Aerobic Plate Count , Bacillus cereus , Enterobacteriacae , Coliforms , Yeast & Mould

 

[olenazh]

We're dairy production, swabbing surfaces for Listeria, water - for TC & E. Coli, air - for Y&M, products - for TC, E. Coli, Y&M, Listeria. I don't think you should test water for Y&M, never heard of it.

[Brothbro]

If you haven't already, take a look at 3M's handbook on environmental monitoring. It's a good resource, and can be used to develop your own monitoring program.

Attached Files

•  3M Environmental Monitoring Handbook.pdf   4.55MB   29 downloads

[Charles.C]

Hi all,

We have a very small Lupin manufacturing company. We are trying to get BRCGS certified. We are classed low risk. However, for environmental monitoring what microbes should we be testing for?

Presently, we do Ecoli, Coliforms, TPC.

Should we be considering Listeria and Salmonella? For Drains? 

We dont use any animal products. We have outsourced some of our products. They come back to us only for packing. 

 

We use UV filtered rain water. What tests should we be looking at? We are doing Heterotrophic colony @22 deg C and 36 Deg C and coliforms. What else would be required?

Please can anyone advise

Thankyou

Looks like you are attempting compliance to EC Norms. If so, maybe add any additional water requirements as per their Directive ?

 

IMO detailed comments as to value of trending pathogens, etc requires knowledge of your process and currently available microbial data.

[gina0509]

Looks like you are attempting compliance to EC Norms. If so, maybe add any additional water requirements as per their Directive ?

 

IMO detailed comments as to value of trending pathogens, etc requires knowledge of your process and currently available microbial data.

Our process is very simple. Lupin grains- milled- flour / flake.

Flour- packed as such. And used in making pasta. No egg used. Just flour and water.

Flake used in premixes like cookie, protein bars, breakfast cereal. This process is outsourced. So we send Flake to 3rd party and they use our recipe for premixes and send it back to us. We pack and dispatch. 

We have never had any pathogens/ Indicator detected in product or environmental swabbing.

[AJL]

Looks like brothbro has shared a good resource. You do have to consider what is relevant for YOUR process. 

Personally if you are low risk, I would take the bare minimum required from a regulatory standpoint. 

Most Food authorities expect you swab for listeria. Salmonella can also be relevant, especially in low water activity processes actually. 

But consider your process, what the regulations say around this product, and develop a RELEVANT risk based schedule. It will looke NOTHING like a schedule from the dairy industry.   

That would be totally irrelevant to use a starting point. 

Good luck! 

[Charles.C]

Our process is very simple. Lupin grains- milled- flour / flake.

Flour- packed as such. And used in making pasta. No egg used. Just flour and water.

Flake used in premixes like cookie, protein bars, breakfast cereal. This process is outsourced. So we send Flake to 3rd party and they use our recipe for premixes and send it back to us. We pack and dispatch. 

We have never had any pathogens/ Indicator detected in product or environmental swabbing.

Hi gina,

 

Thks yr details.

 

As I understand your finished product is NRTE and no heat involved in its processing. I hope/assume that heat is involved if your product is subsequently used for RTE products.

TBH, your product micro. comments seem somewhat remarkable/improbable as per above.

I assume there are no Regulatory requirements relevant to yr product.

I anticipate that pathogen monitoring within EMPG is redundant but also note my comment in Post 5.

[gina0509]

Hi gina,

 

Thks yr details.

 

As I understand your finished product is NRTE and no heat involved in its processing. I hope/assume that heat is involved if your product is subsequently used for RTE products.

TBH, your product micro. comments seem somewhat remarkable/improbable as per above.

I assume there are no Regulatory requirements relevant to yr product.

I anticipate that pathogen monitoring within EMPG is redundant but also note my comment in Post 5.

 

Hi Charles,

Thanks for your comment.

Yes all except 2 are NRTE. Flakes can be eaten raw- sprinkled on smoothies and shakes and Breakfast cereal with milk. Apart from flake, cereal has different nuts, Quinoa and Hemp. (Side Note- We are thinking of phasing out the Cereal soon. If we do that 6 months before the Audit, do we still need to provide Auditor with micro testing results, NIP etc for it ? Shelf life is 6 months)

 

Pasta- We dry it In-House. The data can be downloaded.

 

Yes, our premixes will be  used to bake.

 

There are only 2 companies making Lupin Products here and so we are just trying to figure out the best way to be Audit ready.

Really appreciate your remarks.

[jfrey123]

Our process is very simple. Lupin grains- milled- flour / flake.

Flour- packed as such. And used in making pasta. No egg used. Just flour and water.

Flake used in premixes like cookie, protein bars, breakfast cereal. This process is outsourced. So we send Flake to 3rd party and they use our recipe for premixes and send it back to us. We pack and dispatch. 

We have never had any pathogens/ Indicator detected in product or environmental swabbing.

 

I've been really liking comparing ingredients to the FDA's new Guidance for Ingredient Hazard Analysis lately.  It's fairly comprehensive.

Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food - Appendix 1 Tables (fda.gov)

 

On page 47 for Beans>Single component whole, dried:  they list Lupins specifically, and call out biological hazards as Bacillus cereus, Clostridium botulinum, C. perfingens, Pathogenic E. coli, Salmonella spp.  Page 49 calls out Milled Grain Products>Seed or bean: Pulse: and here it calls out only Clostridium botulinum.  Maybe take a gander at this and decide in your process which items might be of concern to your process.

 

The rainwater collection would make me nervous, but I'm not seeing if you use it as an ingredient or only washing.  I'd want to also test it for salmonella due to concerns about bird droppings contaminating the run off.  And the efficacy of the UV sterilizer would need to be on file and spot on.

[Charles.C]

Hi Charles,

Thanks for your comment.

Yes all except 2 are NRTE. Flakes can be eaten raw- sprinkled on smoothies and shakes and Breakfast cereal with milk. Apart from flake, cereal has different nuts, Quinoa and Hemp. (Side Note- We are thinking of phasing out the Cereal soon. If we do that 6 months before the Audit, do we still need to provide Auditor with micro testing results, NIP etc for it ? Shelf life is 6 months)

 

Pasta- We dry it In-House. The data can be downloaded.

 

Yes, our premixes will be  used to bake.

 

There are only 2 companies making Lupin Products here and so we are just trying to figure out the best way to be Audit ready.

Really appreciate your remarks.

Hi gina,

 

It's an interesting product. I did a little googling and found one typical specification and an interesting process link which are attached below. The micro spec. is rather impressive as stated although lacks a few potential hazards eg L.mono. (However also see "flour" comment below)

 

 Specifications-Lupin-Flour.pdf   858.72KB   8 downloads

 

https://thelupinco.c...akes-naturally/

 

Since there is no directly bactericidal step in the process, FDA as referred in Post 10, probably (conservatively) regard the beans as potentially containing a  range of typical environmental microbial pathogens.  Can compare data with milled flours which have less hazards presumably in part due to the further processing although (slightly illogically?) may gain L.monocytogenes. (Cake flour mixes have become somewhat notorious regarding their users licking raw cake doughs off their fingers and thereby "acquiring" Salmonella).

 

IMEX BRC's audit rigor (and required auditable data) is likely to depend on the Scope of Products which you request to be covered/certified. NRTE is logically less audit "sensitive" as compared to RTE.

[gina0509]

I've been really liking comparing ingredients to the FDA's new Guidance for Ingredient Hazard Analysis lately.  It's fairly comprehensive.

Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food - Appendix 1 Tables (fda.gov)

 

On page 47 for Beans>Single component whole, dried:  they list Lupins specifically, and call out biological hazards as Bacillus cereus, Clostridium botulinum, C. perfingens, Pathogenic E. coli, Salmonella spp.  Page 49 calls out Milled Grain Products>Seed or bean: Pulse: and here it calls out only Clostridium botulinum.  Maybe take a gander at this and decide in your process which items might be of concern to your process.

 

The rainwater collection would make me nervous, but I'm not seeing if you use it as an ingredient or only washing.  I'd want to also test it for salmonella due to concerns about bird droppings contaminating the run off.  And the efficacy of the UV sterilizer would need to be on file and spot on.

Thank you so much Jfrey123.

Yes, I am going ahead with testing for Clostridium Spp and also thinking of including Aspergillus, Penicillium for Afla and Ochra toxins.

I have considered the possibility of bird dropping contamination of the rainwater. Hence will be including Salmonella and E.coli . Apart from these 2, do you reckon it would be a good idea to consider any other Enterobacteriaceae members? 

[jfrey123]

Thank you so much Jfrey123.

Yes, I am going ahead with testing for Clostridium Spp and also thinking of including Aspergillus, Penicillium for Afla and Ochra toxins.

I have considered the possibility of bird dropping contamination of the rainwater. Hence will be including Salmonella and E.coli . Apart from these 2, do you reckon it would be a good idea to consider any other Enterobacteriaceae members? 

 

My experience is limited to what I know, and I'm not smart enough to contemplate all of the implications of rainwater going into my facility, but it would scare the crap out of me if I was a QA Manager in such a plant lol.  Perhaps the company providing your UV purifier can help identify the potential hazards which they are tuned for counteracting?  I'd hope they're able to provide some type of validation that their process makes the muckiest of mucky water safe for food processing...

[Charles.C]

Thank you so much Jfrey123.

Yes, I am going ahead with testing for Clostridium Spp and also thinking of including Aspergillus, Penicillium for Afla and Ochra toxins.

I have considered the possibility of bird dropping contamination of the rainwater. Hence will be including Salmonella and E.coli . Apart from these 2, do you reckon it would be a good idea to consider any other Enterobacteriaceae members? 

 

Must admit I didn't notice yr usage of rainwater. IMO this is likely auditorially to be an immediate Red Flag unless appropriately controlled. Typically, (BCP) compliance is needed to be demonstrated with respect to Local Regulatory Standards for Food Production, eg a Local Potable/Drinking Water Standard, eg  -

 

https://www.irishsta...9/made/en/print

 

I presume there is some reason for this, IMEX, unorthodox choice ? No Choice ?