10 replies to this topic

[makeeno]

Hi all,

I just recently got the job as an SQF Practitioner and the company I work for currently does end product testing daily. People I have talk to say we are over testing. I want to cut back on the testing since none of our customers require us to test our product. I was looking at how can I get this done and still be safe. We do ATP testing of equipment, but I was also wondering how often do I need to do that if I do decide to stop testing the end product daily.

 

Thank you in advanced.

[Scampi]

What type of FG do you produce?   RTE or RTC...........

[makeeno]

What type of FG do you produce?   RTE or RTC...........

RTE

[Scampi]

Ok, so you'd need to perform ATP after sanitation activities every time, and set pass / fail rates where a reclean needs to happen

 

There's nothing wrong with wanting to reduce your testing HOWEVER, you need to validate your decision, as it's a major change to your haccp plan, specifically as a finished good control, so you should also give your entire plan a reassessment to ensure you've got enough other process controls in place to cover off micro issues in order to drop FG testing

 

If you've had any negative tests where the batch wasn't released for sale, the facility is NOT ready for this step

[makeeno]

Ok, so you'd need to perform ATP after sanitation activities every time, and set pass / fail rates where a reclean needs to happen

 

There's nothing wrong with wanting to reduce your testing HOWEVER, you need to validate your decision, as it's a major change to your haccp plan, specifically as a finished good control, so you should also give your entire plan a reassessment to ensure you've got enough other process controls in place to cover off micro issues in order to drop FG testing

 

If you've had any negative tests where the batch wasn't released for sale, the facility is NOT ready for this step

Do I need to ATP test the whole production line or what do you recommend gets tested? We have never gotten a micro issue with our testing. They have always come back below the set levels. What other process controls should I check if I want to go down this route?

[Scampi]

You need to perform your hazard analysis again without this control......that should tell you any other process controls you need

 

I would put all pieces of equipment into the ATP dashboard and swab, say 10 per day, or whatever gets you through the entire line in a week

 

Why did the testing start in the beginning?  What was the rational?   Do you have any CCPs in the process?

 

Need more info to be really helpful

[MOHAMMED ZAMEERUDDIN]

Hi all,

I just recently got the job as an SQF Practitioner and the company I work for currently does end product testing daily. People I have talk to say we are over testing. I want to cut back on the testing since none of our customers require us to test our product. I was looking at how can I get this done and still be safe. We do ATP testing of equipment, but I was also wondering how often do I need to do that if I do decide to stop testing the end product daily.

 

Thank you in advanced.

Hi Makeeno,

Over testing & under testing both are not advisable. Testing shall focus on the critical parameters which are having a direct impact on the food safety. e.g. rinse water or swab testing after cleaning of the machines, microbiological parameters, pH.  Beside these parameters, testing those which are mentioned in the regulation of the respective country food laws. Frequency of the testing is all depend on your risk assessment and testing result trend.

[Dorothy87]

Hi, 

 

As long as you have a tracker of all results you can prepare a new risk assessment. Ensure you have a clear view of all testing and frequency (at least 12 months) 

 

Check HACCP and find out what was the reason of implementation and frequency. Sometimes it could be a retailer extra requirement, and the technical department instead of reviewing existing measures is adding extras to the current list.

 

:)

[makeeno]

Thanks for all the input. So a little more information, it is a RTE filled eclair and filled puff. Both have a kill step for the egg batter and the pudding/filling is frozen/ refrigerated until time to use. The data from the last 3 years 2021-2023 of daily product testing we have only have to retest for pathogens 6 times. 2 times in 2021, 3 times in 2022 and only once this year. The current system I picked up they only do ATP testing once a year. The standard for food analysis is anything under 150 cfu/g is ok anything higher requires a retesting for pathogens, E coli, salmonella, Staph, and Listeria. These were the requirements established by a customer over 20 years ago. Since then it has become the norm, but I have been trying to find ways to change it. Is 3 years of data and only 6 instances where we had to retest a good start? I want to up the ATP to daily to get some data going as well but how long do I have to do daily for before I can say its ok to switch to weekly? Would more ATP testing help me with the analysis of switching from daily product testing?

[kingstudruler1]

I would agree that your current program doesn't make sense.   

 

While i'm not very familiar with your product, 150 CFU/g (i'm guessing tpc/apc) (if its coliform/EB we have another story) is very low.   It also tells you very little.   You don't know if the 150 are all harmless or not.   Scientifically, it does make much sense to me that at 151 CFU/ gram the product is somehow at a higher risk.   If you want to continue with a daily micro test, it would make more sense to me to use something like coliform or enterobacter.  Then test for pathogens if the the sample is positive.  In general proving a product is safe by conducting micro testing is scientifically / statistically not valid.   It does somewhat serve a purpose for validation.

 

With that said, you probably should have a more comprehensive ATP program.   Yearly testing doesn't make sense to me since your product is RTE and higher risk.  I would use ATP testing every time you clean(as scampi stated you don't necessarily have to). I would focus on those processes that you have indicated as having a sanitation preventative control / those after the lethality steps.  

 

Do you have an EMP program?

[Tony-C]

Hi makeeno,

 

 

Welcome to the IFSQN forums

 

I would tread very carefully when reducing testing on a RTE product that is perishable. I am assuming that the finished product requires refrigeration or freezing? Please confirm that is correct and the shelf life of the product.

 

From the information you have posted so far, it seems that your product is likely to be considered High-Risk according to the SQF Food Safety Code - High Risk Food:

Food or food product with known attributes for microbiological growth, physical or chemical contamination, or which may allow for the survival of pathogenic microbial flora or other contaminants which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak.

 

Typical daily tests for RTE perishable products include TVC, Entero and Y&M. Any out of specification results should be investigated. I would retest first before conducting pathogen testing but also have a program of pathogen testing of finished product, which would typically be monthly.

 

ATP testing via swabs/rinses is useful and I would also conduct these tests daily to verify cleaning for RTE perishable product lines.

 

Once you have an established system that you are confident is consistently producing a satisfactory product then you could consider what reduction in product testing could be achieved with minimal risk.

 

Kind regards,

 

Tony