I just started as the QA Manager at a new dehydrated meals manufacturing facility two days ago. Already, dealing with a major issue. The past QA Manager left the company in April 2025, and the facility was without QA Management for 5 months.
The past QA manager often extended shelf life (for Best Before Dates) of various spices, freeze dried vegetables, freeze dried cheeses, powders, and herbs. They primarily used supplier granted extensions, or a combination of in-house Aw testing and third party testing (APC, Coliform, Molds, Yeast) if supported by supplier. In the 5 months since they left, operations extended the shelf life of 25 different spices, dried chilies, dried fruits, and herbs using ONLY organaleptic and in house Aw testing, and used these ingredients with "extended" shelf lives in many different finished products. The majority of Aw measurements came in between .2-.4, with the highest being .58 .
I am at a LOSS for what to do here. I've started by placing all expired raw ingredients that weren't properly tested and extended on hold. For finished products that have already been made with these ingredients...??? Do I send in a representative sample of finished product lots for APC, Coliform, Molds, Yeast and hope for the best? Put all finished product that used these ingredients on hold? Lean on Aw, original COA, and storage conditions and scientific evidence to address inherent risks to each product (ie inherent risk of salmonella, original COA showed a negative result, water activity is well below .85 and product has been stored unopened in a dry environment) and chalk it up as a devitation? Prepare myself for a market withdrawl?
OH, we also have an AIB audit in two weeks :)
Thank you in advance!!