10 replies to this topic

[Jersey Cows]

Good afternoon all, 

 

First, I want to say that this forum has been so incredibly helpful. Thank you all for that. I have a question about Hazard analysis. We currently do not have any sort of radiological hazards our spices aren't irradiated, and our water is tested annually for radium, etc. Is it acceptable for SQF if we leave the radiological hazard under the "Chemical" hazard and note what each hazard category encompasses? In a small "key at the bottom of each H.A. 

 

Thank you in advance :) 

[SQFconsultant]

YES and question, what is water used for in your facility and with that is there a reason why you only test it once a year?

[Jersey Cows]

YES and question, what is water used for in your facility and with that is there a reason why you only test it once a year?

Thank you for responding. Excellent. Our water is used in cheesemaking and is pasteurized. We have city water, and our city provides us with a water quality report annually. We do also send a water sample to a separate external lab for potability testing, just as verification.  

[SQFconsultant]

You will find that you'll need to do better than getting a city water quality report, especially for an SQF Auditor - we test independently 3 times yearly with the same processes.

[jfrey123]

I think the way you're listing radiological would be fine.  It's fine if the hazard is non-existent, it just takes some type of note in your HA to reflect that you have evaluated it at each stage.

 

As for some of these notes about water, eventually an auditor is going to tell you the annual report from the city is insufficient.  Water potability should be tested for verification at each point you use it within the plant (faucets, hoses, handwash stations, etc.), as each of those points can introduce hazards and become harborage points on their own.  If you haven't been doing this routinely in the past, I'd test all use points for a few months until you can establish a history of clean results before moving to a quarterly or bi-annual frequency. 

[Jersey Cows]

I think the way you're listing radiological would be fine.  It's fine if the hazard is non-existent, it just takes some type of note in your HA to reflect that you have evaluated it at each stage.

 

As for some of these notes about water, eventually an auditor is going to tell you the annual report from the city is insufficient.  Water potability should be tested for verification at each point you use it within the plant (faucets, hoses, handwash stations, etc.), as each of those points can introduce hazards and become harborage points on their own.  If you haven't been doing this routinely in the past, I'd test all use points for a few months until you can establish a history of clean results before moving to a quarterly or bi-annual frequency. 

Great thank you. Any water used in any food product is pasteurized before adding and its approximately 5 gallons to 2000 gal of product. The system is cleaned by a CIP system. Water from hoses, buckets, barrels or anything of that sort is not used for any processing step. Our pasteurizer and CIP are documented via recording charts to show the entire process. 

[Shrimper]

I think everyone has made a great point. One thing, though, we currently use the city's water quality reports during audits but as an additional doc. I would not have that as the only document, but having that additionally could not hurt. Even adding water to your environmental monitoring (i.e. swab the water/ice for coliforms) could be something to help build a history. 

[G M]

In addition to radiological you may find that hazards recognized for other foods or ingredients may be standard risks for others, but not for your ingredients or process.  It may be helpful to have an appendix or accessory document that lists all the risks you have considered and rejected for a stated reason with some basic reference -- some auditors might want to ding you for a point if your risk assessment of things considered not to be a risk aren't documented too.

[Jersey Cows]

I think everyone has made a great point. One thing, though, we currently use the city's water quality reports during audits but as an additional doc. I would not have that as the only document, but having that additionally could not hurt. Even adding water to your environmental monitoring (i.e. swab the water/ice for coliforms) could be something to help build a history. 

Thank you. Yes, water is part of our environmental monitoring program. We test for E.coli and coliforms using an external laboratory. 

[Bo16]

Also, check the area around your plant, in our case we have a nuclear power plant less than 50 miles from the plant.  In the case of a substantial leak (as determined by the US NRC) we may be required to hold any food product until release has been issued by the NRC.  (Not that we would have any employees coming to the plant to ship product if there was possible exposure)

 

Chances of this are remote, but I am old enough to remember the three mile island Nuclear power plant meltdown in 1979 and although the release of radioactive gas did not reach a level that impacted the population, it could have. 

 

Check the laws in your country. 

[GMO]

Good afternoon all, 

 

First, I want to say that this forum has been so incredibly helpful. Thank you all for that. I have a question about Hazard analysis. We currently do not have any sort of radiological hazards our spices aren't irradiated, and our water is tested annually for radium, etc. Is it acceptable for SQF if we leave the radiological hazard under the "Chemical" hazard and note what each hazard category encompasses? In a small "key at the bottom of each H.A. 

 

Thank you in advance :) 

 

Note that spices being irradiated does not mean they would be a radiological hazard.  Lots of products are x-rayed but you don't consider it a risk.  My understanding and that other auditors have shared of this clause to comply with FSMA is it's more around where products are sourced.  So in one site we were sourcing produce across the UK, we did look at proximity to nuclear power plants and record this assessment.  In another site, we sourced sea salt from Anglesey and for people outside the UK (and many inside) they may not be aware how much historical nuclear waste has gone into the Irish sea.  So on that, we asked the suppliers to confirm they have done some testing to ensure it doesn't impact their salt.  

British people will know of how in some areas of Wales, restrictions were in place for over 20 years due to the fall out from Chernobyl (it rains a lot on Wales and they were unfortunate that the rain that day carried fall out isotopes with it.)

 

To my mind it's going to be a pretty infrequent risk.  And we used to include it into our chemical section but proved (by considering some low risk specifics) that in our hazard analysis we'd considered it.