7 replies to this topic

[oahr1996]

Hello,

 

My facility performs annual finished product adulterant testing in March using a composite of finished product lots manufactured in the prior year, which have already been distributed to customers. The composite is analyzed for heavy metals, mycotoxins, pesticides, and microbiological hazards. A positive result could necessitate a recall of all lots represented in the composite.

The site is evaluating its Monitoring Program to identify alternative sampling and testing strategies that reduce potential recall exposure while maintaining regulatory and food safety compliance.

 

What best practices or alternative approaches have you used to limit recall scope associated with post-distribution composite testing? How could I conduct the annual testing in March without using material from the previous year?

 

Thank you!

[SHQuality]

What kind of products and raw materials are we talking about?

 

While I've seen heavy metals as part of annual screenings, mycotoxins, pesticides and microbiological hazards have always been part of per batch testing in the places where I've worked. If you decide on an annual monitoring plan, it should be backed up by a significant history of negative test results that show the risk is small enough for testing to be scaled down like this.

 

So can you elaborate how your facility came to work this way? Do suppliers do any testing, do you do any testing other than the annual test to confirm the results your suppliers give are truthful?

 

If your composite finished products contain any herbs and spices, I wouldn't recommend testing for pesticide contamination only once a year.

[GMO]

Wow, way to create a massive recall window!

 

Ultimately the purpose of this testing is to reduce risk to consumers. So you may want to think about a few things:

 

Where is the contaminant likely to be introduced?

How likely is the contaminant to be there?

How severe is the food safety hazard?

 

That should help determine your frequency and testing location.

For example, if you have ground spices, I'd include some heavy metal testing, pesticide and possibly micro if you're not using them in a cooked product but I'd do so on the spices before use. I'd hold the batch, test it, then release it. Holding the batch is only because if it fails then you will be initiating a recall if it's been used.

 

Likewise if you're not fully cooking your product, depending on what it is, and pathogens could cause consumer harm, I would test finished product for an appropriate micro suite but more than once a year and I would do so while the product is in market because I should be confident of my processes on site. If not, I'd get that sorted.

 

Mycotoxins may be in ingredients or, potentially generated in storage on site depending on your ingredients and how long you store. I'd expect some level of ongoing Y&M testing as indicators though, more than 1 per year.

[Scampi]

I would re-evaluate your sampling process altogether

 

IF you feel that FG testing is required, then it seems to me, your frequency should increase exponentially     

 

what's the point of testing material that is 11 months old and likely consumed already

 

what are you trying to prove following your current method  OR are you just ticking a box?

[MDaleDDF]

Agree with all before me that this is a bad way to go about it.   When I path test I place the product on hold until path results come back, only then will I ship it.   

I know some places mix lots for testing to 'save money', but you'll lose all the money you saved as soon as there's a recall with that method imho.   

I test finished product quarterly, positive release as I already stated.   That eliminates almost all risk of a recall happening in the first place (other than a supplier screwin me, which has happened once).

 

To me lab testing is one of the cheaper and easier things I do.  I don't understand why some places sit on their hands when it comes to finished testing...

[SQFconsultant]

We test as we go - waiting a year after everything has been consumed sounds like what Scampi mentioned - ticking a box off.

[Shrimper]

When product arrives as incoming raw material, put it on hold, send out for testing, then - assuming results are fine -release it for whatever your process it (packaging, rework, sales, etc.). If testing results are poor, then the product is contained and already on hold. 

[kconf]

You can start by testing one thing at a time per sample, rather than preparing a composite.