Basic GMP & HACCP

Hello:

This is Yong. I need your advice on the below issues.

1) Is there any specific requirement for the cleaning utensil used e.g. brush. Any specific material or any specific colour?

2) I knew that the maximum size allowed by the FDA for foreign particle presence in baby food is 7mm. Is there any revision for that standard? For me, 7mm is very big. [Our company using the metal detector that can detect the metal pieces below 2mm. Personnally, I think that 2mm is still quite big]

3) My friend is working in a bakery plant. According to her consultant, baking process may not be a critical control point as baking is necessary to make the thing 'cooked' and ready to be eaten and not a step they purposely implemented to eliminate pathogen. Any idea regarding this comment?

1) Is there any specific requirement for the cleaning utensil used e.g. brush. Any specific material or any specific colour?

I’ll take question 1. If you take a look at the link below you can see that hygienic brushes are made from stainless steel, solid polypropylene and polyester and can be autoclaved. The preferred colour for bristles is blue as there is no blue food and potential contaminants can be more easily identified.

http://www.hillbrushinc.com/hbi-user

I don’t know what if any standards require the above.

Regards,
Simon

Dear Simon,

No.1
Very Interesting brush link. Looks particularly aimed at animals, such as the "beastie" brushes .
I have never seen a stainless steel brush in a food factory, used for what ?? Cleaning the robots ?
I have also never seen people autoclaving food factory brushes - hospital ??
The colour is problematic - since it can be argued that small pieces of embedded plastic are not likely to be a safety hazard, one might prefer a less emphatic colour than blue, although blue is probably better than black !! . I don't recall ever seeing a standard actually specifying this unlike plasters.

No.2
I recall the 7mm ref. however I think there are many documented cases of baby food producers recalling lots due to metal particles of much smaller size. There is a long thread on this somewhere in the forum.

No3
Am not bakery person but I would have guessed there are microbiological implications in the baking step. If so, as you noted there will presumably be CCP consequences. No doubt a baking person will elaborate soon on typical HACCP for this.

Rgds / Charles.C

Rgds / Charles.C

No.1
Very Interesting brush link. Looks particularly aimed at animals, such as the "beastie" brushes .
I have never seen a stainless steel brush in a food factory, used for what ?? Cleaning the robots ?
I have also never seen people autoclaving food factory brushes - hospital ??
The colour is problematic - since it can be argued that small pieces of embedded plastic are not likely to be a safety hazard, one might prefer a less emphatic colour than blue, although blue is probably better than black !! . I don't recall ever seeing a standard actually specifying this unlike plasters.

I use stainless steel brushes on Newsgirl every day, directly after she's been autoclaved. She moans a bit but it polishes her up lovely.

The brushes are specifically for food hygiene, the same company has an outlet in the UK. I have seen their brushes used a lot, especially blue. It may be just a British thing.

Simon

Dear Yong,

I missed this thread earlier but cannot resist wondering if using thermal treatment during baking step is not a CCP then what is. Perhaps the Consultant has chemical preservatives as CCP in mind. I find this approach to risk assessment extremely interesting. How then should micro organisms be prevented, removed or reduced to an acceptable level?

Basic understanding of identifying a "kill step" is indeed essentially vital during hazard analysis. Your friend should not just accept decison at point blank but rather ask consultant for justification in reaching such a risk assessment decision.
Regards
Charles Chew

Dear YongYM:


1) It depends on the way you look into this issue. We were arguing this issue before in the meeting. Finally we changed from using metal scrub to plastic scrub. If you use metal steel brush, your metal detector will be able to detect metal contaminates in your end product (if it's bigger than 2mm). If you use plastic brush, recommended blue color, metal detector won't be able to detect the residue, but if you do visually 100% inspection, it will help.

2) As far as I know, FDA still amended the same regulation regarding the size of foreign matter in food.


Best regards,
Jenny

Dear All,

I wonder when someone will bring out a safe plastic detector, preferably a blue one.

I'm not sure why but it seems to me from observation on the net that US companies in general are much more prepared to initiate recalls for things like metal contaminants even though below official stds than other countries. Possibly related to the potential legal claims of not doing anything or simply social responsibility

Rgds / Charles.C

Dear All,

I wonder when someone will bring out a safe plastic detector, preferably a blue one.

I'm not sure why but it seems to me from observation on the net that US companies in general are much more prepared to initiate recalls for things like metal contaminants even though below official stds than other countries. Possibly related to the potential legal claims of not doing anything or simply social responsibility

Rgds / Charles.C

I would guess claims avoidance over social responsibility Charles.

Dear All,

I wonder when someone will bring out a safe plastic detector, preferably a blue one.

Here's one:

http://www.ecc-ltd.c...ble-brushes.htm

It's worth checking though because I have found metal detectable plastics to be very variable. A cable tie required the whole tie to be in there and a metal detectable glove required the whole glove! I'd phone them up, ask for a free sample and test the bristles through your machine to check they work before ordering.

Dear GMO,

Very good searching

The company name has a rather intriguing sound also.

Certainly an ingenious expansion of the (presumably) more justifiable blue plaster concept. One doesn't wish to find metal contamination in the product therefore we add metal to all our factory implements!. They don't seem to actually specify what the metal is ?

I also noticed this claim -

Even the smallest of Particles are detectable and rejectable

Hmmm.

Must say that I hv rarely seen any actual statistics of injuries caused by plastic contamination, even the brittle variety. Possibility of overkill here ?

Rgds / Charles.C

Possibly but if a customer found plastic in their food and reported it to an EHO doesn't mean it won't cause you problems. Hard plastics can be just as harmful as glass.

3) My friend is working in a bakery plant. According to her consultant, baking process may not be a critical control point as baking is necessary to make the thing 'cooked' and ready to be eaten and not a step they purposely implemented to eliminate pathogen. Any idea regarding this comment?

I know this is an old post, but have come across this situation with 2 HACCP audits and with a HACCP Trainer.
The reasoning for the baking process not being a CCP is that if the product is not baked to the time and temperature that would qualify as a kill step, you will not have a viable (saleable) product. For baked goods to rise and bake to a finished product you would have to have them at higher than 165⁰ F for longer than 1 minute.
If you end up with a viable product, you have effectively killed pathogens. If you don't have a viable product, it does not matter whether you have killed anything or not as it ends up in the waste can.

The key to this is the "viable product" if the step fails.

Hope this helps.

Tom

The reasoning for the baking process not being a CCP is that if the product is not baked to the time and temperature that would qualify as a kill step, you will not have a viable (saleable) product. For baked goods to rise and bake to a finished product you would have to have them at higher than 165⁰ F for longer than 1 minute.
If you end up with a viable product, you have effectively killed pathogens. If you don't have a viable product, it does not matter whether you have killed anything or not as it ends up in the waste can.

The key to this is the "viable product" if the step fails.

Hi Tom

Whilst I understand your view here, I cannot agree totally with what you are saying.
Your logic may apply to some baked products but not all. If I was an auditor, depending on your product, I may take the view that the step is still a CCP and you have decided your control measure is to reject non viable products.

Critical Control Point (CCP) is a point, step or procedure at which controls can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable (critical) levels. Flour will contain several microbiological hazards.

Have a look here at some info from Greencore:

Examples of CCPs in a Bakery

Regards,

Tony

Hi Tom

Whilst I understand your view here, I cannot agree totally with what you are saying.
Your logic may apply to some baked products but not all. If I was an auditor, depending on your product, I may take the view that the step is still a CCP and you have decided your control measure is to reject non viable products.

Critical Control Point (CCP) is a point, step or procedure at which controls can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable (critical) levels. Flour will contain several microbiological hazards.

Have a look here at some info from Greencore:

Examples of CCPs in a Bakery

Regards,

Tony

Well I would disagree with their definition of CCP- that example seems to have "Quality CCPs" and "Safety CCPs" - but to be frank HACCP is not about quality - it's only about Food Safety. If you have quality attributes - they are definitely CPs - Control Points, but not critical in the true sense of HACCP.
And depending on the process, baking in an oven may very well not be a CCP. At our facility we make tortillas which spend only a short time in the oven.

Hi Tom

Whilst I understand your view here, I cannot agree totally with what you are saying.
Your logic may apply to some baked products but not all. If I was an auditor, depending on your product, I may take the view that the step is still a CCP and you have decided your control measure is to reject non viable products.

Critical Control Point (CCP) is a point, step or procedure at which controls can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable (critical) levels. Flour will contain several microbiological hazards.

Have a look here at some info from Greencore:

Examples of CCPs in a Bakery

Regards,

Tony

Hi Tony,
Looking at the Greencore site it has quite a bit of information. Not knowing the exact process, IMO, I might guess that there are too many CCPs.

In my understanding, if there is a point downstream that will control a hazard, then anything previous might not be a CCP. I have attached a Process Hazard Analysis that we use in our HACCP program. Have a look at column 5 for my "viable product" theory. This is from a program accredited by the International HACCP Alliance.

Section7_13.pdf   363.97KB   385 downloads

While I agree with your definition of a CCP above, I have also some additional criteria for what makes a Critical Control Point. I quote from the training Powerpoint (because I only have it in multiple page .pdf) regarding the criteria for a CCP...
1. Must be a process step
2. Last opportunity to eliminate or reduce to an acceptable level a food safety issue
3. The process will produce a viable product, if the process step fails
4. The process step is there for no other reason than food safety.

I am in no way an expert on this, but as my Bakery is being put through the rigors of an SQF audit which includes HACCP, I need discussions like this to see where my faults may lie.

Thanks for any input.

Tom