42 replies to this topic

[TimG]

 

 And now, they are trying to get us to admit something  that is not true. They want a corrective action, but I am not sure how to go about this without them forcing us to admit something is wrong when in fact there is nothing wrong.  

 

As long as I had all my ducks in a row and made sure I wasn't in the wrong even a little, I would straight-faced, with 0 regret make a detailed corrective action and list the root cause as 'lack of training or understanding on the part of USDA inspector.'

Corrective action, 'demand better training or understanding by USDA inspector regarding what constitutes a non-compliance?'

Edited by TimG, 10 February 2025 - 05:17 PM.

[jfrey123]

I'm wondering if the QC tech who responded not knowing what the stuff was is the root cause here.  If OP is reviewing and saying it's the normal/expected level from the smoking process, the QC tech should've been able to tell the USDA right there that it was byproduct from the smoking process.  But by saying "yeah, I don't know what that black stuff is", the USDA gets to make up whatever they want to think it is in their statements.  "QC could not identify black contaminates, possibly dirt from floor" is now a thing they get to write up.

[GMO]

I find this genuinely baffling they're missing the point that there is a food safety risk the USDA are just ignoring to have some BS statement with their obsession with claiming some level of adulteration.  What do I know hey?

[irheavyd]

They have accepted that it is creosote.  

[irheavyd]

Apparently it is acceptable as long as you can't see it with the naked eye.  They know it is in all wood smoked product.  But, since you can see these with the naked eye then all of a sudden it is contaminated.  And its ok in there eyes if we just wipe it off.  But in order to do that we have to do a corrective action the way they want us to.  Just not willing to do that because then we will be locked into something that is based off of nothing.  i did an ASKFSIS question and they responded saying that it is not a contaminate.  They later backtracked on that statement after, I am assuming, somebody in the chain of command told them to.  I wish some of these big companies could chime in on this as it will effect them as well.

[GMO]

I will stop going on now.

 

But back to the point I raised previously, even if they are drastically overstating the level of creosote / tar on the product, does this not indicate build up more than over one batch / production run and so ineffective cleaning?  Would the preventive action then not be around effective cleaning?  If it's pipework can it be made quick release so it can be effectively scrubbed and wet clean and spares fabricated so you can swap them in and out?  

[FSQA-USDA]

What is the cleaning frequency for the smoker, and how long does it take for the creosote buildup to become noticeable? How clean does the smoker look like during Pre-Operational inspection that it passed QA and USDA inspection? How clean does the smoker look like during Operational inspection that it passed QA inspection?

 

Based on the cited regulations, this is a sanitation noncompliance. There is an excessive buildup of creosote in the smoker. Does the NR support the current retention of product after you have provided all the scientific support and AskFSIS? No, I believe they have no standing based on the information provided. However, the NR remains valid as the conditions prove that the SSOPs are insufficient to prevent insanitary conditions, and the cited regulations supports that conclusion

.

Assuming this is a walk-in oven with an attached wood smoker, I have seen over 50 similar smokers, and only one had excessive black buildup of creosote, which was at a non-inspected smoking facility. The other ovens were nearly spotless, even after smoking products for 18 hours with continuous back-to-back operation. From my observations, such a buildup of creosote is a result of inadequate cleaning frequency. The regulation clearly states that "facilities, equipment, and utensils used in the operation of the establishment must be cleaned and sanitized as frequently as necessary to prevent the creation of insanitary conditions and the adulteration of product." This buildup indicates that the frequency of sanitation is inadequate and needs to be increased in the SSOP’s.

 

Now, let's address how you can resolve this issue using the regulations. Corrective actions for SSOP are cited in 9 CFR 416.15(b): “Corrective actions include procedures to ensure appropriate disposition of product(s) that may be contaminated, restore sanitary conditions, and prevent the recurrence of direct contamination or adulteration of product(s), including appropriate reevaluation and modification of the Sanitation SOP's and the procedures specified therein or appropriate improvements in the execution of the Sanitation SOP's or the procedures specified therein.”

1. Disposition of products that may be contaminated:

Refer to your AskFSIS statement which clearly indicates that creosote is not a contaminant; thus, the product is not considered contaminated, thus, does not need to be disposed. Next…

1. Restore sanitary conditions:

Thoroughly clean the smokers and/or replace the pipes, then show the inspector. Next…

1. Prevent recurrence of direct contamination or adulteration of product, including reevaluation of SSOP:

Your AskFSIS confirms there is no contamination issue, but does not address "adulterated." According to 9 CFR 301.2, the term "adulterated" has several meanings, but the relevant one here is: “(4) If it has been prepared, packed, or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health.” Once again, the AskFSIS states that creosote is not a contaminant. The fix? Increase the sanitation frequency of the smokers to satisfy the recurrence prevention aspect of the corrective actions.

Edited by FSQA-USDA, 06 March 2025 - 03:30 PM.

[TylerJones]

My Background: Smoked Meats. Location NE USA

 

After reading through OP comments I believe your sanitation frequencies are not sufficient.

I say this with experiecing almost the same thing without being tagged by the USDA.

 

We used to use old bick chimney style smokers over hardwood fires to smoke our products. The chambers were extremely dry and there was no added water / steam / showers. The creosote would stick to the inside of the chimneys and we would scrub them once every 3 months. We would move the product to another room to begin cool down showers.

 

We have since switched over the pellet style smokers that have too many bells and whistles. 

The new smokers can add steam to keep a good humidy % helping with yields and making a consistant product  Once the product hit temp at kill step the smoker automatically goes into a shower mode to start the cooling process. The water pressure is high and the dang thing just about cleans itself during this process. After a day or 2 I noticed black drips inside the chambers and realized we were not cleaning appropiately. We now do a wash down at the end of every shift, including all positive / negative airflow fans / smoke transfer pipes and do not see any issues. 

 

My belief is you need to clean more frequently and you will seen an improvement. I would not argue with the USDA and do a cleaning study based on findings after each batch / daily / weekly until this risk is reduced. How many cooks are you doing in a 16 hr. window? Do you introduce humidity or showers inside your chambers?

[GMO]

 

We used to use old bick chimney style smokers over hardwood fires to smoke our products. The chambers were extremely dry and there was no added water / steam / showers. The creosote would stick to the inside of the chimneys and we would scrub them once every 3 months. We would move the product to another room to begin cool down showers.

 

 

Wow.  This is eye opening.  I've only ever visited plants smoking cheese and spices.  All had stainless steel construction with stainless pipework venting the steam into the chamber.  Brick is not a suitable material for food manufacturing.  And once every 3 months is nowhere near enough.  Glad to hear you've changed process.

 

When I commented before I was imagining some of the stainless style smokers I've seen.  

 

Wow.  Amazing that these exist.

[BM5]

My experience: Cheese smoking, North West England.

 

I worked as TM at a dairy only smokery for a couple of years and as a TM for a large cheese wholesaler that did a small amount of smoking for about 17 years. 

 

We used Afos kilns that would take about 1 ton of cheese at a time, smoke for 8 hours and cleaned daily and refilled, we never had any drips on the product and every piece of cheese from 150g Brie to 10kg slabs of cheddar was immaculate.

 

They should be cleaned daily to prevent build up of tar, if not from a safety perspective, certainly a quality angle.

 

On PAH's I was part way through conducting a study with Lancaster University on the removal of PAH's during the smoking process using verious filtering systems and the imapct it would have on product quality and smoking times.

 

Sadly I didn't complete the project as I left the business but I did quite a bit of research in to PAH's in cheese smoking.

[TylerJones]

GMO- my plant has been in continous operation for 100 years using the brick chambers before we switched. 3 months of cleaning was sufficent as I mentioned the chambers were dry and had no humidity.

 

I base my findings off of RA's and frequency validations rather than speculation. We were SQF 9.0 certified smoking over open fire pits in the brick chimney's before we purchased stainless steel smokers. There are many plants that still use the original system.

[GMO]

My experience: Cheese smoking, North West England.

 

I worked as TM at a dairy only smokery for a couple of years and as a TM for a large cheese wholesaler that did a small amount of smoking for about 17 years. 

 

We used Afos kilns that would take about 1 ton of cheese at a time, smoke for 8 hours and cleaned daily and refilled, we never had any drips on the product and every piece of cheese from 150g Brie to 10kg slabs of cheddar was immaculate.

 

They should be cleaned daily to prevent build up of tar, if not from a safety perspective, certainly a quality angle.

 

On PAH's I was part way through conducting a study with Lancaster University on the removal of PAH's during the smoking process using verious filtering systems and the imapct it would have on product quality and smoking times.

 

Sadly I didn't complete the project as I left the business but I did quite a bit of research in to PAH's in cheese smoking.

 

Thanks... This thread was making me think I was going mad.  

[GMO]

GMO- my plant has been in continous operation for 100 years using the brick chambers before we switched. 3 months of cleaning was sufficent as I mentioned the chambers were dry and had no humidity.

 

I base my findings off of RA's and frequency validations rather than speculation. We were SQF 9.0 certified smoking over open fire pits in the brick chimney's before we purchased stainless steel smokers. There are many plants that still use the original system.

 

Hey, I accept that I know nothing about your process.  But "it was ok for 100 years" I'm going to have to say is not a great reason to say it's still ok.

[irheavyd]

That is not what I am saying.  And I am not saying its ok.  But, there are no regulations that govern this at all.  We know what it is.  It is natural creosote.  Which is actually an additive in liquid smoke that is approved by USDA.  So for them to say that it is a contaminant makes no sense to me.  They are still trying to get us to agree that it is a sanitation issue and that it is a contaminant.  If we do that they will take everything off hold.  Not sure that is such a good idea.  Could open us up for a whole other can of worms.

[irheavyd]

My experience: Cheese smoking, North West England.

 

I worked as TM at a dairy only smokery for a couple of years and as a TM for a large cheese wholesaler that did a small amount of smoking for about 17 years. 

 

We used Afos kilns that would take about 1 ton of cheese at a time, smoke for 8 hours and cleaned daily and refilled, we never had any drips on the product and every piece of cheese from 150g Brie to 10kg slabs of cheddar was immaculate.

 

They should be cleaned daily to prevent build up of tar, if not from a safety perspective, certainly a quality angle.

 

On PAH's I was part way through conducting a study with Lancaster University on the removal of PAH's during the smoking process using verious filtering systems and the imapct it would have on product quality and smoking times.

 

Sadly I didn't complete the project as I left the business but I did quite a bit of research in to PAH's in cheese smoking.

Cheese smoking is entirely different than meat smoking.  Temperatures are different as well as the time.  Also, the creosote is one of the things that gives the smokey flavor in the meat.  Some smokehouses let it build up a bit to increase the flavor.

[irheavyd]

My Background: Smoked Meats. Location NE USA

 

After reading through OP comments I believe your sanitation frequencies are not sufficient.

I say this with experiecing almost the same thing without being tagged by the USDA.

 

We used to use old bick chimney style smokers over hardwood fires to smoke our products. The chambers were extremely dry and there was no added water / steam / showers. The creosote would stick to the inside of the chimneys and we would scrub them once every 3 months. We would move the product to another room to begin cool down showers.

 

We have since switched over the pellet style smokers that have too many bells and whistles. 

The new smokers can add steam to keep a good humidy % helping with yields and making a consistant product  Once the product hit temp at kill step the smoker automatically goes into a shower mode to start the cooling process. The water pressure is high and the dang thing just about cleans itself during this process. After a day or 2 I noticed black drips inside the chambers and realized we were not cleaning appropiately. We now do a wash down at the end of every shift, including all positive / negative airflow fans / smoke transfer pipes and do not see any issues. 

 

My belief is you need to clean more frequently and you will seen an improvement. I would not argue with the USDA and do a cleaning study based on findings after each batch / daily / weekly until this risk is reduced. How many cooks are you doing in a 16 hr. window? Do you introduce humidity or showers inside your chambers?

 

 

We have modern smokers and they run basically 24 hours a day with steam, humidity, and showers.  They are washed down daily, but the piping is weekly.  Even after a full clean, there are still spots.  We have spoken to the oven manufacturer as well and they say it is unavoidable. 

[sanidadexterior]

Hello, one question: Isn't creosote a wood preservative?

It appears the EPA is reviewing its registration.

Creosotes can contain PAHs, phenols, and cresols.

Perhaps the problem is due to smoking meat using creosote-treated wood.

Greetings from Spain

[GMO]

Hello, one question: Isn't creosote a wood preservative?

It appears the EPA is reviewing its registration.

Creosotes can contain PAHs, phenols, and cresols.

Perhaps the problem is due to smoking meat using creosote-treated wood.

Greetings from Spain

 

I raised the issue on PAHs and got shot down.