FCS TPC swab results high - need help justifying that food safety was never compromised

Hello, I work for a poultry processing company. We process only raw product (no RTE), thus fairly low risk as the product is cooked to internal temp of 165 before consumption. However I've got a couple problems I need help working through... As part of our environmental monitoring program, we swab 10 surfaces monthly and test for APC, E-coli and Coliforms to validate sanitation. The swabs are sent to third party lab and we don't receive the results until 2 days later. Our FC scales failed the initial APC swab. Standard procedure in this situation is to notify the sanitation team so they can preform a deep clean that night, then the surface can be re-swabbed the following morning. The scales failed the re-swab. The results are shown below. Initial swab (1 scale swabbed) 

6600 cfu/swab

Re-swab (6 scales swabbed)

28600 cfu/swab

380 cfu/swab

170 cfu/swab

10 cfu/swab

<10 cfu/swab

<10 cfu/swab

1. I need advice/help justifying that food safety was never jeopardized, as we continued to use these scales in the days prior to receiving the results. Does anyone know of any resources that touch on acceptable levels of APC in raw chicken. I am hoping to justify that since there is a kill step later in the process (when the consumer cooks the chicken) the high plate count is no cause for concern, but cant find any reference material to support argument.  2. I am not very familiar with sanitation procedures. Does anyone have any suggestions on what is the best chemicals to use on these scales to prevent this problem from re-occurring?  Appreciate any insight you may have. Thanks 

I work for a company that manufactures and supplies sanitation chemicals. Your standard degreaser/scrub soap should be fine. If it can address the other areas in your plant then it should be strong enough for the scales. The issue more than likely is one of two things:

1. Poor sanitation and the surface wasn't thoroughly cleaner, or

2. Poor rinsing or rinsing with high pressure hose. Bullet nozzles are not conducive to rinsing detergents from equipment and often leave elevated numbers for swabs, even though the surface may be clean. The soap residual could cause a false positive. Many soaps needs a low pressure, high volume rinse to properly be rinsed. 

Also, make sure your detergent has a sufficient level of rinse agents in it.

Hello,

I think that you may benefit from using an ATP based system for daily monitoring of sanitation. You can ATP the surface, then swab for lab samples. If any ATP value is high you can correlate that to a dirty surface. For High ATP values you can re-clean re-sanitize on the same day of swabbing, this may prevent the 2 day wait. 28, 600 CFU / per swab does seem high for a scale surface but maybe the swab was not handled correctly. Contamination of lab samples can also occur. I would start by retraining the person sampling the location and the person doing the cleanup for the scales, also check cleaning chemicals concentrations. As to raw chicken CFU values, it can be very high but you can show that with your own historical data.

I hope it helps!

Juan

I second the ATP swabs, we use the same, but it sounds like we're not talking food contact surfaces?  So maybe no help here?  I swab every week before starting manufacturing with ATP, and quarterly I do path testing on non-food contact surfaces.   I'm not in the poultry biz though, so I can't comment on your frequency, etc.

As far as justifying food safety wasn't in jeopardy, I don't see how you can do that with two positives.   At my place, this would trigger a CAR, product testing, etc.  If this were me, I'd have no way around it after two failed tests.  And everything we make also has a kill step, but that doesn't matter, or isn't the point.   Your results are outside of what you say is acceptable, so your EM system is compromised regardless. 

Don't you have a work instruction or SOP that basically tells you what you have to do reaction wise?   I know for me it says in my EM paperwork that one failed swab, I reswab/retest the area 3 times after the cleaning SOP has been run on the area.   If it's dirty again, CAR is triggered, etc etc.

I'll be curious to read other thoughts on this one...

Hello, I work for a poultry processing company. We process only raw product (no RTE), thus fairly low risk as the product is cooked to internal temp of 165 before consumption. However I've got a couple problems I need help working through... As part of our environmental monitoring program, we swab 10 surfaces monthly and test for APC, E-coli and Coliforms to validate sanitation. The swabs are sent to third party lab and we don't receive the results until 2 days later. Our FC scales failed the initial APC swab. Standard procedure in this situation is to notify the sanitation team so they can preform a deep clean that night, then the surface can be re-swabbed the following morning. The scales failed the re-swab. The results are shown below. Initial swab (1 scale swabbed) 

6600 cfu/swab

 

Re-swab (6 scales swabbed)

28600 cfu/swab

380 cfu/swab

170 cfu/swab

10 cfu/swab

<10 cfu/swab

<10 cfu/swab

 

1. I need advice/help justifying that food safety was never jeopardized, as we continued to use these scales in the days prior to receiving the results. Does anyone know of any resources that touch on acceptable levels of APC in raw chicken. I am hoping to justify that since there is a kill step later in the process (when the consumer cooks the chicken) the high plate count is no cause for concern, but cant find any reference material to support argument.  2. I am not very familiar with sanitation procedures. Does anyone have any suggestions on what is the best chemicals to use on these scales to prevent this problem from re-occurring?  Appreciate any insight you may have. Thanks 

Hi ntay,

As indicated previous posts you probably need to provide more info. to get a meaningful response.

My area of expertise is not slaughtering poultry so apologies in advance if these queries have well-known answers.

Is the primary objective of yr post the further utilization of Scales rather than chicken meat ? Or is the data on Scales being used as an indicator for the condition of the meat ?

What is the cleaning procedure prior to micro swabbing ? If none or random, then the swab results are probably, comparitively, meaningless.

Is this an existing/official  routine procedure ? If so, have you previously validated this procedure ? If no, has anyone else validated it ?. If validated, what are the associated target levels for the micro data mentioned ?

Note that the micro. data you are discussing are all  unrelated to Safety. (I assume the E.coli referred is "generic")

Safety is related to microbial Pathogens.

PS - re yr query APC "raw chicken" - for what form of chicken meat ??? eg retail pack raw chicken breast ? (notorious for typical existence of Salmonella).

a

Hi ntay,

 

As indicated previous posts you probably need to provide more info. to get a meaningful response.

 

My area of expertise is not slaughtering poultry so apologies in advance if these queries have well-known answers.

 

Is the primary objective of yr post the further utilization of Scales rather than chicken meat ? Or is the data on Scales being used as an indicator for the condition of the meat ?

 

What is the cleaning procedure prior to micro swabbing ? If none or random, then the swab results are probably, comparitively, meaningless.

 

Is this an existing/official  routine procedure ? If so, have you previously validated this procedure ? If no, has anyone else validated it ?. If validated, what are the associated target levels for the micro data mentioned ?

 

Note that the micro. data you are discussing are all  unrelated to Safety. (I assume the E.coli referred is "generic")

 

Safety is related to microbial Pathogens.

 

PS - re yr query APC "raw chicken" - for what form of chicken meat ??? eg retail pack raw chicken breast ? (notorious for typical existence of Salmonella).

I second the ATP swabs, we use the same, but it sounds like we're not talking food contact surfaces?  So maybe no help here?  I swab every week before starting manufacturing with ATP, and quarterly I do path testing on non-food contact surfaces.   I'm not in the poultry biz though, so I can't comment on your frequency, etc.

As far as justifying food safety wasn't in jeopardy, I don't see how you can do that with two positives.   At my place, this would trigger a CAR, product testing, etc.  If this were me, I'd have no way around it after two failed tests.  And everything we make also has a kill step, but that doesn't matter, or isn't the point.   Your results are outside of what you say is acceptable, so your EM system is compromised regardless. 

 

Don't you have a work instruction or SOP that basically tells you what you have to do reaction wise?   I know for me it says in my EM paperwork that one failed swab, I reswab/retest the area 3 times after the cleaning SOP has been run on the area.   If it's dirty again, CAR is triggered, etc etc.

I'll be curious to read other thoughts on this one...

Hello,

 

I think that you may benefit from using an ATP based system for daily monitoring of sanitation. You can ATP the surface, then swab for lab samples. If any ATP value is high you can correlate that to a dirty surface. For High ATP values you can re-clean re-sanitize on the same day of swabbing, this may prevent the 2 day wait. 28, 600 CFU / per swab does seem high for a scale surface but maybe the swab was not handled correctly. Contamination of lab samples can also occur. I would start by retraining the person sampling the location and the person doing the cleanup for the scales, also check cleaning chemicals concentrations. As to raw chicken CFU values, it can be very high but you can show that with your own historical data.

 

I hope it helps!

 

Juan

Thank you everyone for the response.

My apologies for the lack of information.

To clarify, we do ATP swabs weekly and swabbing once a month. But that is a great tip to do ATP after swabbing so I don't run into the same problem again. 

The scales are food contact surfaces, we use them to size our chicken breasts.

The two fails trigger a deviation report (which includes a food safety assessment, corrective actions and preventative actions). I do not have support from my boss to send any of the product for microbial testing, which is why I’ve been searching for some reference material/ a deeper understanding on APC swab results on food contact surfaces in relation to poultry.

In regards to the primary objective of my post. I am conducting a food safety assessment as this is part of our procedure when we receive a repeat fail on the same item. And I need to determine/justify if food safety was compromised. i.e., does a swab result of 28600 cfu on the scale (a food contact surface) jeopardize the safety of the chicken breasts processed on it.

The cleaning procedure prior to micro swabbing is the standard pre-rinse, apply chemical detergent, scrub/remove all soil, then rinse the detergent from the equipment with high-pressure water. Then we swab in the morning before applying sanitizer.

This is an existing procedure; we have established target levels:

APC: <100CFU

Total Coliforms: <10

Generic Ecoli: <10

Please note that all other food contact surfaces have produced swab results for all three metrics <10CFU.

The comment from Charles... 

“Note that the micro. data you are discussing are all  unrelated to Safety. (I assume the E.coli referred is "generic")

Safety is related to microbial Pathogens.

PS - re yr query APC "raw chicken" - for what form of chicken meat ??? eg retail pack raw chicken breast ? (notorious for typical existence of Salmonella).”

Could you please expand on this?

Thanks again everyone for the help. It’s so appreciated.  

 NACMCF-Micro.Criteria for Foods,USA,2015.pdf   1.8MB   38 downloads

Page 152 may help justify your results

For me most of this info is still moot.   You exceeded the limitations you yourself set in your system, twice.   In my world that triggers an investigative reaction.

What is your scope if you don't mind my asking?   BRC?  FSSC 22k? 

For me most of this info is still moot.   You exceeded the limitations you yourself set in your system, twice.   In my world that triggers an investigative reaction.

What is your scope if you don't mind my asking?   BRC?  FSSC 22k? 

The repeat fail did trigger an investigation, which I am in the process of completing... a food safety assessment where we determine the disposition, corrective actions and preventative actions. But sending samples to the lab for micro testing isn't an option unfortunately, looking for alternative ideas.

We have a HACCP program and are in the early stages of working towards SQF. 

Ah, I see.   Well if you have no cert this is a much easier problem to solve.   After you're sqf it'll be a whole new bag of ****!   Lol.

It seems if you ran a cleaning sop and it still swabbed dirty, you have a few things to zero in on.   Either the sop is ineffective, or the samples were contaminated before testing?  This is assuming up till now your testing has been reliable and non-problematic?

If it were me, I'd stand and watch them clean it, and swab immediately after.   But my building is certainly different than yours.    The 26800 result is pretty high to be a contaminated sample imho, but who knows.   Sounds to me like that scale was missed?

Regardless, good luck to you!

 

Thank you everyone for the response.

 

My apologies for the lack of information.

 

 

To clarify, we do ATP swabs weekly and swabbing once a month. But that is a great tip to do ATP after swabbing so I don't run into the same problem again. 

 

 

The scales are food contact surfaces, we use them to size our chicken breasts.

 

 

The two fails trigger a deviation report (which includes a food safety assessment, corrective actions and preventative actions). I do not have support from my boss to send any of the product for microbial testing, which is why I’ve been searching for some reference material/ a deeper understanding on APC swab results on food contact surfaces in relation to poultry.

 

In regards to the primary objective of my post. I am conducting a food safety assessment as this is part of our procedure when we receive a repeat fail on the same item. And I need to determine/justify if food safety was compromised. i.e., does a swab result of 28600 cfu on the scale (a food contact surface) jeopardize the safety of the chicken breasts processed on it.

 

The cleaning procedure prior to micro swabbing is the standard pre-rinse, apply chemical detergent, scrub/remove all soil, then rinse the detergent from the equipment with high-pressure water. Then we swab in the morning before applying sanitizer.

 

This is an existing procedure; we have established target levels:

APC: <100CFU

Total Coliforms: <10

Generic Ecoli: <10

Please note that all other food contact surfaces have produced swab results for all three metrics <10CFU.

 

 

The comment from Charles... 

 

 

“Note that the micro. data you are discussing are all  unrelated to Safety. (I assume the E.coli referred is "generic")

 

Safety is related to microbial Pathogens.

 

PS - re yr query APC "raw chicken" - for what form of chicken meat ??? eg retail pack raw chicken breast ? (notorious for typical existence of Salmonella).”

 

Could you please expand on this?

 

 

 

Thanks again everyone for the help. It’s so appreciated.  

 

Hi ntay,

^^^ - Please clarify the "this" ? ( eg Note the "subtle" comments concerning Salmonella in linked data of Post 8)(APC/coliform data may also be optimistic, inter alia)

^^^ (blue) - Data / test method may not be very appropriate IMO. (micro shd include effect of sanitizer)

For example see -

http://www.ifsqn.com...ces/#entry60958