2 replies to this topic

[ETHAN BAUER]

Hello,

 

We manufacture candy in Texas, USA and currently are a Soy Free facility. We have purchased an ingredient that is "soy free" but still list's that it was manufactured in a facility that processes soy.

 

Since we are soy free, we will test each finished batch of candy for soy. After testing is complete and the batch is negative, it may move to packaging. The cooking tools used for the batch will be cleaned, sanitized, and tagged for pre-op inspection.

 

Should I add this as a CCP  since we are controlling an allergen or just leave it as an SOP?

Edited by ETHAN BAUER, 28 August 2023 - 03:50 PM.

[jfrey123]

Are you testing in-house for soy or sending to a third party lab?  I think the time between manufacture and testing would preclude this from being a CCP.  In my plants, this situation is a SOP relying on supplier approval:  we have customers tell us where allergens may be stored in a facility or used on a shared product line for items they send to us.  If shared lines, we request copies of their allergen control program(s), evaluate how it can affect our products.  A few have raised concerns where we listed their status as "conditional" on our supplier register while we tested products before use, and once we had a baseline of good results, we approved the supplier.

 

If you have sufficient concerns about cross-contamination from this vendor after reviewing their programs, I'd recommend testing the material they supplied *prior* to using it in your run.  Would be a helluva thing to spent man hours and other raw material input just to learn you can't use the finished product.

[kingstudruler1]

I'm with Jfrey on this.   The supplier is controlling the hazard (or at least should be).  Testing product is not normally considered an effective CCP.   Hazards such as pathogens usually are not equally dispersed and sampling and testing is not always likely to indicate an issue.  

 

When you say CCP are you referring to HACCP or a preventative controls plan?

 

The customer controls the hazard.   Your testing, third party audits, etc are validation that the hazard is being controlled.  I too would test prior to use.