RTE Treated Spices
I wasn't sure how to ask this question.
I am working with a company that processes Spices. Everything we process has been treated except for Dehydrated Garlic and Onion Powder (3 log reduction)
I have a customer QA auditor that has questions many times how we can sell Garlic and Onion Powder untreated as a RTE product.
We have offered to have his product treated at a cost, but he insists that's not the point, he wants to know how we can run it on the same lines with treated product as other customers will take it that way. But based on what I have seen in industry, most companies are not treating garlic and onion powder and the FDA isn't policing it looking for a 5-log reduction. Ownership will get it pushed through because the company needs us to package their product. But how do I justify it to the QA Auditor?
I wasn't sure how to ask this question.
I am working with a company that processes Spices. Everything we process has been treated except for Dehydrated Garlic and Onion Powder (3 log reduction)
I have a customer QA auditor that has questions many times how we can sell Garlic and Onion Powder untreated as a RTE product.
We have offered to have his product treated at a cost, but he insists that's not the point, he wants to know how we can run it on the same lines with treated product as other customers will take it that way. But based on what I have seen in industry, most companies are not treating garlic and onion powder and the FDA isn't policing it looking for a 5-log reduction. Ownership will get it pushed through because the company needs us to package their product. But how do I justify it to the QA Auditor?
I get the feeling they're hinting more at the fact that plants can "validate" that their process is effective in reducing/preventing contamination.
Maybe go online and pull articles that would support your point of 'most companies are not treating garlic and onion powder'
..., he wants to know how we can run it on the same lines with treated product as other customers will take it that way. ...
Order of operations. It seems to be an aseptic technique cross-contamination problem he is suggesting you are introducing to other products from the alliums.
Example: The equipment is fully cleaned, then a treated product 'A' runs on the line, followed by an untreated product 'B', followed by a treated product 'C'
A meets its treated label claims,
B meets its non-treated label claims.
C is now contaminated post-treatment, and probably can't be sold as 'treated' anymore, because the line wasn't cleaned between B and C.
Does treatment = ETO, irradiation, etc?
I would always purchase treated product when possible.
However, do you know its not safe without a "treatment"? Is the supplier stating that the product is not RTE? The supplier is requried to produce a safe product - unless you are you providing written assurances that you are controlling the hazard and /or the product marked "not processed to control X hazard". I understand the written assurances are not being enforced. That doesnt change the law tho.