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Nature of contaminants for NC raised during BRC/IFS audit

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ilonar

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Posted 13 June 2019 - 07:33 AM

During our BRC/IFS Food audit, we received the following NC: the hazard analysis does not take into account the possible storage in the same cold room of fruits and vegetables/various packaging/spare parts or parts of packaging material.

 

Whoever has experience in the fruit and vegetable sector knows that fresh fruit and vegetable are generally stored on pallets with 100-200 carton/plastic boxes (sometimes fully covered) of either loose product (lets say 5 kg of loose cherry tomatoes in a box) or pre-packed product (10 punnets of 500 g strawberry). And in most of the cases on the top of this pallet you also have a pallet cover for extra protection. The packaging material is packed in closed carton boxes; all packaging material of the same type are stored on the same pallet. We are aware of the fact that product and packaging material should be stored separately in different storage rooms, but we always have the audit during the peak of the season, when all extra square meter is necessary.

 

I started doing the hazard analyses and my first question was what kind of contaminants can I have?

- microbiological: the probability that there will be a cross-contamination from the pallet with packaging material is just the same like from the one with product. I would say that the one from the other product is even higher: if the product is already class 2 and with mold, then you have with what to have the cross-contamination. At a butcher or a slaughter house, I can imagine that the carcasses are not stored in the same cold room with all the packaging material, but for fruit and vegetable (low risk) I don't see any problem.

- chemical: I also don't see what kind of chemical contaminants can get from the pallet with packaging material to the one with product. Of course, migration of packaging material is discussed in the HACCP plan at general hazards

- physical: there might be contaminants on the boxes with packaging material: plastic, metal, wooden pieces, which could fall during the transport of the pallets and contaminate the product. But I can't figure out anything else.

 

And a last possible contaminant: feces of pests on boxes with packaging material which could fall in the product. And in this case besides physical, I would also go for microbiological contamination.

 

Does anyone have another idea or doesn't agree with my way of seeing the hazards?



mahantesh.micro

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Posted 13 June 2019 - 08:17 AM

Dear ilonar,

 

All that you noted are correct in my point of view, you can add some more like residues of fumigant from wooden pallets (if wooden pallets are used), possible cross contamination of pesticides used for fruits and vegetables (if unwashed and in case pesticides used for some vegetables and not used for others). Pest also one of the carriers of contaminants.

 

Mahantesh



Nadim

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Posted 14 June 2019 - 11:57 AM

i would also consider about allergens.. any contaminattion to the packaging.



Charles.C

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Posted 15 June 2019 - 03:33 AM

hi ilonar,

 

Apologies for my ignorance of yr business but I am somewhat unclear as to the actual process (Z) being carried out and which steps of it involve the use of the sole (??), cold (chilled??) room (XYZ) being discussed.?

 

I anticipate that any potential/significant  safety hazards will derive from either (a) "BCPA"  cross-contamination (cross-contact) opportunities within XYZ or (b) "B" micro growth.opportunities within XYZ .

 

(a,b) may presumably relate to -

 

(1) specific process activities/steps involving room XYZ

(2) specific items involved in (1), eg safety-related BCPA conditions of food/packaging materials involved

(3) specific contact possibilities in (1), eg product/product, product/packaging, packaging/packaging

(4) temperature control room XYZ

 

IMO, in order to evaluate 1-4 for potential/significant hazards, need more context/detail.


Kind Regards,

 

Charles.C


ilonar

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Posted 15 June 2019 - 07:46 AM

Hi Charles.C,

 

We are a company which is (re)packing fresh fruit and vegetables. As a simple example, we receive boxes with 4 kg bulk blueberries and pack them in punnets of 250 g blueberries. we receive the entire spectrum of fruit and vegetables, and the activities that we perform can be either a similar repacking like already explained or just a short term storage after which the product is dispatched to clients. According to BRC, we are a low risk company. The cold room is used to store "raw materials", so the product before repacking or preparing for dispatch. the temperature is set either for 3C or for 12C, depending on the season and storage room availability.  All products are stored on wooden pallets and handled within the cold store with a forklift or pallet jack.

 

Ilona



Charles.C

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Posted 17 June 2019 - 07:26 PM

Hi Charles.C,

 

We are a company which is (re)packing fresh fruit and vegetables. As a simple example, we receive boxes with 4 kg bulk blueberries and pack them in punnets of 250 g blueberries. we receive the entire spectrum of fruit and vegetables, and the activities that we perform can be either a similar repacking like already explained or just a short term storage after which the product is dispatched to clients. According to BRC, we are a low risk company. The cold room is used to store "raw materials", so the product before repacking or preparing for dispatch. the temperature is set either for 3C or for 12C, depending on the season and storage room availability.  All products are stored on wooden pallets and handled within the cold store with a forklift or pallet jack.

 

Ilona

 

Hi ilonar,

 

Thks for process details.

 

I assume only safety-related hazards are being discussed, ie not including sensory/quality factors.

I assume finished products are categorised as RTE.

I assume packaging materials food-safe.

I assume not vac.pack or MAP packaging.

I assume  only fully enclosed product is handled within the storage room.

 

Most Literature seems to regard safety aspects of "Storage" for basic Fruit/vegetable products to be handled via PRP functions.

 

I'm sort of curious as to whether a particular aspect of yr own haccp plan triggered the auditor's interest/query.

 

Assuming packaging integrity is good and breakages are rare, the likelihood of cross-contamination is presumably low. Adequate segregation and appropriate allergenic labelling (if relevant) seem to be quite common items of interest.

Potential hazards of cross-contact are mentioned in previous posts, any significant (safety) severity aspect might be related to the specific items/conditions but offhand seems not particularly likely.

 

I noticed this general FDA comment for microbial safety of raw agricultural commodities (RACs) -

3. Precooling and Cold Storage

Sanitary cold storage of RACs and fresh-cut produce is important to reduce the risk of microbial contamination and potential for subsequent growth. However, most current temperature recommendations for both whole and fresh produce are based on temperatures that maintain quality attributes. Although we recognize that more research needs to be done to identify the types of whole and fresh-cut produce that will support the growth of human pathogens and the temperatures at which this pathogen growth will occur, certain practices can reduce the potential for pathogen growth and contamination during precooling and cold storage.We recommend the following practices to reduce this risk:

  • Holding RACs and fresh-cut produce at appropriate cold storage temperatures to reduce the potential for microbial growth
  • Preventing condensate and defrost water from evaporator-type cooling systems (e.g., vacuum cooling, cold storage) from dripping onto fresh and fresh-cut produce
  • Designing and maintaining forced air cooling to avoid contaminating fresh produce

    In most instances, vacuum cooling or use of fans poses the lowest risk of microbial contamination

  • Holding cut melons and any other fresh-cut product determined to need temperature control for safety at ≤ 41° F (≤ 5° C)
  • Locating temperature monitoring devices in the warm area of the refrigerator unit (e.g., near the door) and calibrating them on a regular basis
  • Inspecting all refrigeration units on a regular basis and keeping them in good operating condition
  • Storing similar commodities together (unprocessed product next to unprocessed product and finished product next to finished product) to avoid cross-contamination
  • Using an appropriate inventory system to ensure first in first out (FIFO) use and FIFO shipment of raw materials and finished products

https://www.fda.gov/...-and-vegetables

 

These model haccp plans may also be of some interest -

 

Attached File  HACCP Plan,CFIA, Generic Model for Ready-To-Eat Fresh-Cut Vegetables.pdf   2.53MB   38 downloads

(eg steps 15/16)

Attached File  HACCP_Plan_Wholesale_Fruits_and_Vegetables.pdf   248.74KB   33 downloads

Attached File  HACCP_Plan_Fruit_Salad.pdf   69.44KB   27 downloads

 

PS - mould is not usually regarded as a safety-related hazard.


Kind Regards,

 

Charles.C


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