14 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. 

[oahr1996]

Thank you everyone for your responses!

 

To clarify - every finished product lot is tested for micros and other specific parameters before it is allowed to be released to a customer. The pesticide, mycotoxins, and heavy metals reports are only conducted once a year with material that was produced from the previous year. Testing the product from the previous year for the pesticide, mycotoxins, and heavy metals is the issue we are currently running into. So how can we conduct these annual tests (pesticide, mycotoxins, heavy metals) without using product from the previous year?

[SHQuality]

So how can we conduct these annual tests (pesticide, mycotoxins, heavy metals) without using product from the previous year?

Test batches that you can recall if the test results show a contamination is present. 

Instead of making a composite sample, take unannounced samples of all your raw materials/suppliers throughout the year, so you're not stuck with a single big bill in March.

[GMO]

Where are the pesticides, heavy metals and mycotoxins coming from? Unless you're doing a lot wrong, they're from your suppliers, not from your process. Test your ingredients, while they're held ideally.

[kconf]

If you are running all year, why can't you test something that was produced yesterday or last week? And then next month test for something else. This way you will have all the tests done by the end of this year. I don't know your production schedule, but test as you go. 

[oahr1996]

We do run production all year long and only conduct testing for heavy metals, pesticides, mycotoxins as a precaution. Historically, we have never seen over regulation numbers for any of the tests. 

 

If samples were taken from only the last week to be tested for heavy metals, pesticides, and mycotoxins then would this have to be repeated throughout the year or could it be done once and then be done for that year?

[Scampi]

Split WHAT you're testing for across the year

 

month 1   mycotoxins

 

month 4  mercury

 

month 7  heavy metals

 

month 12 pesticides

 

and repeat, or something similar

[SHQuality]

Split WHAT you're testing for across the year

 

...

month 4  mercury

 

month 7  heavy metals

 

Hi Scampi, 

 

Is there a particular reason that you have split mercury from the other heavy metals?

In my experience testing all heavy metals in one go is significantly cheaper and to be honest so far, I've never seen it done differently.

I'd like to hear your view on the matter.