Is touching boxes and par cooked bacon allowed while scaling and packaging?

Hi everyone,

I am from Canada, I am working in the meat processing facility as a QA manager.

This facility is manufacturing sliced par-cooked bacon since last 40 years. When the par cooked bacon bellies gets sliced then the individual take the pre-made carboard box with the plastic liner, keep it on the scale, pick up the bacon slices from the conveyor with the help of scoop and add slices of bacon layer by layer in the box, once the box contains correct weight of bacon, the same individual pick up the box and push it on the other conveyor where it further gets taped and sealed by the other person, followed by the metal detection and palletizing. Staff follow GMP's and wear disposable gloves and sleeves while handling the boxes and product through out the process.

My question: Is touching boxes and par-cooked bacon slices simultaneously ok as per SFCR or GFSI standard? If we have sufficient process validation studies done to prove that the risk is low and finished product is safe and do not posses any food safety risk to the consumer , then can it be helpful to resolve any potential regulatory non compliance?

 Can anyone please put some input in this?

To make sure I got this right: you've got a person who puts a secondary package on a scale, adds a food grade poly liner into it, then grabs and adds bacon until it hits the right weight before lifting and carrying that same secondary package to a conveyor?  Sounds super iffy for those hands to go from direct food contact to a secondary package over and over and over throughout a shift, especially with a wet product like bacon.  Does this employee also assemble the boxes (running a taping machine or tape gun with the same hands that'll grab bacon)?

I'd imagine an auditor would love to ding this practice and cite 1,385 hypothetical scenarios why it's not a good idea.

To make sure I got this right: you've got a person who puts a secondary package on a scale, adds a food grade poly liner into it, then grabs and adds bacon until it hits the right weight before lifting and carrying that same secondary package to a conveyor?  Sounds super iffy for those hands to go from direct food contact to a secondary package over and over and over throughout a shift, especially with a wet product like bacon.  Does this employee also assemble the boxes (running a taping machine or tape gun with the same hands that'll grab bacon)?

 

I'd imagine an auditor would love to ding this practice and cite 1,385 hypothetical scenarios why it's not a good idea.

Hi There,

Thank you so much for replying. The bacon is not wet , the temperature of the bacon slices is almost 0 degree Celsius, the employee uses scoop to pick the bacon slices from the conveyor and touches the bacon when weighing the final weight manually on the scale. but yes there is a constant touching between secondary packaging and the par-cooked bacon slices. There is an another employee who assemble ,and tape the boxes. and you are absolutely right , that auditors are questioning a lot about this process, although we have risk assessment study done, and no pathogen or biological hazard observed in the finished product or the secondary packaging, also, the product is par cooked, and there is an instruction on the label to fully cook the product above 160F for the food safety before consumption. In your experience, if the risk assessment shows low risk for this process and product is par cooked, then still its not a good idea to proceed with right?

jfrey123 said.....  " I'd imagine an auditor would love to ding this practice and cite 1,385 hypothetical scenarios why it's not a good idea."

I did a walk with an auditor one day and something similar was happening - he looks at me and says ---- "I don't know why it's wrong, exactly, but this is wrong and well, I'll figure out how to write this up by the end of the day"  

I thought F*ck, are you kidding me!!!!!!

It never made it on the report nor was it discussed at the outbriefing -- must have worked thru that 1,385 and thought better of it. LOL

Two questions: Do you consider cardboard to be a sanitary or product contact surface?  Do you require personnel to wash their hands after handling something that isn't sanitary before returning to product handling?

I don't see any mention of this person washing their hands a thousand times a day.

Maybe the employee who tapes boxes could also place the bags and carry the boxes.

Then your employee touching bacon is only touching the bacon and not the boxes.

Yeah, I'm going to continue to struggle where it's allowed for an employee to jump back and forth between touching food and then a non-food contact surface... But it's not my plant, and if you've got the horsepower to show the auditors you've proven it's not a risk, I'm in no spot to judge.

I'd imagine you're relying on this study you discuss where you maybe tested and didn't pickup any pathogens on your secondary packages at that time.  "It'll work until it doesn't," as my welding instructor would tell us when it came to having dubious employee safety and health practices.  I'm sure you can defend it, saying the product is intended to be cooked so the study shows your secondary package isn't likely to have pathogens and then any slight risk is mitigated by the consumer cooking to the safe temperature.  Hell, works for the tea plants I've toured:  all kinds of handling that I didn't agree with was addressed by stating "we place the tea into bags which controls any foreign material, and the tea is brewed which would kill any pathogen."