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Annadel

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Posted 06 March 2020 - 09:44 AM

If there are no changes in the components or no repair done on the vessels/chambers, how often must heat distribution tests be done?  Is there any (FDA) standard stating required frequency for conducting these tests?  We are a toll-manufacturing plant, and our client requires us to do yearly heat distribution testing to all our retort vessels and smokehouse chambers.  We do not have the necessary tools and equipment, so we make use of a third party service provider (Ellab) to conduct the tests.  Having these tests done is quite costly, so I was thinking of reducing the testing frequency (to maybe every 2 or 3 years), but I need something (a standard) to back me up.  Kindly advise.  Thanks. 



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Posted 09 March 2020 - 05:47 PM

I'd say 2-3 years feels infrequent.  Why not buy the equipment to do it yourself instead?



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Posted 09 March 2020 - 07:29 PM

If there are no changes in the components or no repair done on the vessels/chambers, how often must heat distribution tests be done?  Is there any (FDA) standard stating required frequency for conducting these tests?  We are a toll-manufacturing plant, and our client requires us to do yearly heat distribution testing to all our retort vessels and smokehouse chambers.  We do not have the necessary tools and equipment, so we make use of a third party service provider (Ellab) to conduct the tests.  Having these tests done is quite costly, so I was thinking of reducing the testing frequency (to maybe every 2 or 3 years), but I need something (a standard) to back me up.  Kindly advise.  Thanks.

 

 


 

Not sure about FDA but USDA apparently specifies annual, eg -

 

Attached File  Retort-Processing-Guidelines-02-13-14.pdf   588.96KB   17 downloads

 

PS - The attached FDA document, if appropriate to OP's process, also mentions annual evaluation -

 

Attached File  FDA,The-Domestic-Acidified-and-Low-Acid-Canned-Foods-(PDF).pdf   325KB   18 downloads


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Charles.C


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Posted 09 March 2020 - 11:54 PM

Hi,

 

1. Conduct a risk analysis.

 

2. Prepare a procedure for your verification, like a checklist to inspect your retorts and smoke house chambers.  GMP and monitoring devices should be within your standards and specifications.  Add the frequency of your monitoring, person who will conduct the checklist inspection.

 

3. Include in your  Validation  is the  frequency after you did your risk analysis.

Part maybe of your validation is heat distribution,  or any research that does the heat distribution. You can also say in your procedures that based on the risk analysis, you only require to do a heat distribution every 3 years. Also, you can correlate it with your heat penetration and sensory evaluation of the products you toll pack ( require your customers to conduct a heat penetration of their products).

 

All you have to do is you prove to the Auditor that your retort and smoke house chambers are not a high risk equipment.  I used to work in a tuna canning and pouch plant, we conducted our heat distribution every 5 years and whenever there is a new additional retort or a change in pipes and electrical wire connection of the thermometers.

 

 

Thank you,

Booh



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Posted 10 March 2020 - 12:16 AM

Hi,

 

1. Conduct a risk analysis.

 

2. Prepare a procedure for your verification, like a checklist to inspect your retorts and smoke house chambers.  GMP and monitoring devices should be within your standards and specifications.  Add the frequency of your monitoring, person who will conduct the checklist inspection.

 

3. Include in your  Validation  is the  frequency after you did your risk analysis.

Part maybe of your validation is heat distribution,  or any research that does the heat distribution. You can also say in your procedures that based on the risk analysis, you only require to do a heat distribution every 3 years. Also, you can correlate it with your heat penetration and sensory evaluation of the products you toll pack ( require your customers to conduct a heat penetration of their products).

 

All you have to do is you prove to the Auditor that your retort and smoke house chambers are not a high risk equipment.  I used to work in a tuna canning and pouch plant, we conducted our heat distribution every 5 years and whenever there is a new additional retort or a change in pipes and electrical wire connection of the thermometers.

 

 

Thank you,

Booh

 

Hi Booh,

 

Thks yr input.

 

I assume the OP is producing canned "X" for export to USA. afaik this is Regulatory controlled in respect to Scheduled Process aspects.

 

I anticipate the OP is looking for an official FDA document stating their (import) requirements for canned goods, notably with respect to the retort condition. Perhaps you can provide a link to yr suggested route ?

 

Having once seen pictures of a typical setup for carrying out heat distribution validation, it looked a fairly demanding task. I am impressed that you were able to do it yourself.


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Charles.C


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Posted 10 March 2020 - 05:01 PM

Hi Charles, 

 

We conducted this in our retorts together with a third party laboratory who has all the needed tools and equipments to do it. 

 

In the USA, you have TechniCAL ( some of their personnel are retired, knowledgeable persons from USFDA) who can also conduct in South America specifically, Peru, Ecuador, Argentina, Bolivia, Chile, Argentina etc. 

In the Philippines, there is one very good government owned laboratory who can assists them to conduct the Heat Distribution and Heat Penetration at a cheaper  cost, called Food Development Center, Taguig, Metro Manila.  Food Development Center and USFDA has tie-up on Technical Knowledge and Training. 

Heat Distribution is a challenging work if you don't have the proper tools and equipments. 

 

At Food Development Center, their company can ask for Joyce Masiglat Sales, Director of Food Development Center. They can help her get a cheaper cost if they wanted to conduct their heat distribution on an agreed frequency that they can define in their procedures. 

Their Website is: http://fdc.net.ph/

 

Thank you, 

Booh


Edited by boohblake, 10 March 2020 - 05:09 PM.

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boohblake

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Posted 10 March 2020 - 09:10 PM

If there are no changes in the components or no repair done on the vessels/chambers, how often must heat distribution tests be done?  Is there any (FDA) standard stating required frequency for conducting these tests?  We are a toll-manufacturing plant, and our client requires us to do yearly heat distribution testing to all our retort vessels and smokehouse chambers.  We do not have the necessary tools and equipment, so we make use of a third party service provider (Ellab) to conduct the tests.  Having these tests done is quite costly, so I was thinking of reducing the testing frequency (to maybe every 2 or 3 years), but I need something (a standard) to back me up.  Kindly advise.  Thanks. 

 

https://www.law.corn...fr/text/9/431.6 - Equipment maintenance- at least once a year. 

 

Thanks, 

Booh



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Annadel

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Posted 11 March 2020 - 02:20 AM

Hi Charles, 

 

We conducted this in our retorts together with a third party laboratory who has all the needed tools and equipments to do it. 

 

In the USA, you have TechniCAL ( some of their personnel are retired, knowledgeable persons from USFDA) who can also conduct in South America specifically, Peru, Ecuador, Argentina, Bolivia, Chile, Argentina etc. 

In the Philippines, there is one very good government owned laboratory who can assists them to conduct the Heat Distribution and Heat Penetration at a cheaper  cost, called Food Development Center, Taguig, Metro Manila.  Food Development Center and USFDA has tie-up on Technical Knowledge and Training. 

Heat Distribution is a challenging work if you don't have the proper tools and equipments. 

 

At Food Development Center, their company can ask for Joyce Masiglat Sales, Director of Food Development Center. They can help her get a cheaper cost if they wanted to conduct their heat distribution on an agreed frequency that they can define in their procedures. 

Their Website is: http://fdc.net.ph/

 

Thank you, 

Booh

 

Thanks so much on this, Booh.  Yes, FDC is indeed a less costly choice, but fitting your job request into their schedule is so hard and it will take months before you can avail of their services.  But with our 3rd party service provider (Ellab) increasing their price by 300%, I am actually considering FDC.  Thanks for providing the name of the contact person.  This is most helpful.

 

Regards,

 

Annadel 


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Charles.C

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Posted 11 March 2020 - 02:49 AM

https://www.law.corn...fr/text/9/431.6 - Equipment maintenance- at least once a year. 

 

Thanks, 

Booh

 

Hi Booh,

 

Thk for the reference although I note this is (a) for meat/poultry so presumably under (internal?) USDA jurisdiction, (b) no mention regarding necessity of revalidation of  heat distribution data (differs to unreferenced comment in my attachment/post 3).

 

As per "Equipment", I speculate that "annual" may be a popular choice although clashes Post 4.


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Charles.C


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GMO

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Posted 11 March 2020 - 01:17 PM

I worked in a factory with multiple retorts and I worked in a factory with one.  Both bought their own equipment.  It wasn't actually that expensive.  Honestly, look into it.



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Posted 11 March 2020 - 04:32 PM

Thanks so much on this, Booh.  Yes, FDC is indeed a less costly choice, but fitting your job request into their schedule is so hard and it will take months before you can avail of their services.  But with our 3rd party service provider (Ellab) increasing their price by 300%, I am actually considering FDC.  Thanks for providing the name of the contact person.  This is most helpful.

 

Regards,

 

Annadel 

You are most welcome Annadel, you can schedule a 5 or 10 year plan with them at a certain frequency level of a month and/or date of each year  for your heat distribution, which will be more convenient to you and in agreement with them.   You might also discuss with them a payment plan at your own convenience since you will be using their services more.  This is just some thoughts for you to consider when you talk to their Director. Please send my regards to her when you talk to her. 

 

Regards, 

Booh Blake


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