15 replies to this topic

[tisher]

If I can do a risk assessment on a common area that RTE and NRTE product flows through why can I not do a risk assessment on a common machine/area that is used for RTE/NRTE product?

[SQFconsultant]

If I can do a risk assessment on a common area that RTE and NRTE product flows through why can I not do a risk assessment on a common machine/area that is used for RTE/NRTE product?

Of course you can.

[GMO]

I agree that if a RTE and not RTE product is made on the same machine, you can risk assess it. The outcomes of your risk assessment might be a problem though but it depends on what your products are.

If you're talking cooked pies and raw pies then yes, that will be a problem. If it's just a situation where the non RTE product is actually ok to eat raw it's just cooked for organoleptic reasons then there's no issue.

Perhaps explain your process and maybe we can all talk it through?

[tisher]

I agree that if a RTE and not RTE product is made on the same machine, you can risk assess it. The outcomes of your risk assessment might be a problem though but it depends on what your products are.

If you're talking cooked pies and raw pies then yes, that will be a problem. If it's just a situation where the non RTE product is actually ok to eat raw it's just cooked for organoleptic reasons then there's no issue.

Perhaps explain your process and maybe we can all talk it through?

we are a small meat processing plant. we produce RTE sausages and NRTE sausages. They come out of the smokehouse/cookhouse into a shared hallway and are placed into segregated cooolers for RTE and NRTE respectively. They come out of their respective coolers into one large room(no segregation other than a plastic strip door), basically the room is devided into half. The problem lies with our vacumn packing machine, which is in the room that would be classified as NRTE. I agree that we could not be packing both RTE and NRTE product at the same time on the same machine. I would like to however to set for example:monday, tuesday as RTE packaging days and wednesday,thursday,friday, as NRTE packaging days. If I do a risk assessment in order to use the "hallway"as a shared hallway which product is only passing through, could I not do a risk assessment in the packaging rooms in order to use the areas for both RTE and NRTE with sanitations in between(obviously) on separate days?

[GMO]

we are a small meat processing plant. we produce RTE sausages and NRTE sausages. They come out of the smokehouse/cookhouse into a shared hallway and are placed into segregated cooolers for RTE and NRTE respectively. They come out of their respective coolers into one large room(no segregation other than a plastic strip door), basically the room is devided into half. The problem lies with our vacumn packing machine, which is in the room that would be classified as NRTE. I agree that we could not be packing both RTE and NRTE product at the same time on the same machine. I would like to however to set for example:monday, tuesday as RTE packaging days and wednesday,thursday,friday, as NRTE packaging days. If I do a risk assessment in order to use the "hallway"as a shared hallway which product is only passing through, could I not do a risk assessment in the packaging rooms in order to use the areas for both RTE and NRTE with sanitations in between(obviously) on separate days?

If I understand this correctly, I'm screaming NOOOOOOOOO!!!!!!!!!!!!!!!!!!!

So you have raw sausages and cooked / cured sausages and want to use the same vacuum packing machine? NOOOOOOOOOOO!

Sorry. Panicked.

I refer you to this website from the UK and this comment:

http://www.food.gov....guid/ecoliguide

Some of the key measures highlighted in the guidance to control E.coli are:

• Identification of separate work areas, surfaces and equipment for raw and ready-to-eat food.
• Use of separate complex equipment, such as vacuum-packing machines, slicers, and mincers for raw and ready-to-eat food.

I believe failure to do this was behind an EColi outbreak in Wales. A boy died in that outbreak.

Please let me know if I've misunderstood?

[MQA]

I agree with GMO 100%.

There is always room for error. We're human. RTO & NRTE should always be separated.

To simplify, why else is there a red cutting board for raw meats and a brown cutting board for cooked meats?

[tisher]

What if the VP machine was in a room(on its own) which would be classified as RTE and the NRTE product was bagged before it went into this room for sealing. so there would be no NRTE product exposure.

[RMAV]

What if the VP machine was in a room(on its own) which would be classified as RTE and the NRTE product was bagged before it went into this room for sealing. so there would be no NRTE product exposure.

How do you ensure the exterior of the NRTE bag is not contaminated before it reaches the RTE room and VP machine?

[GMO]

Completely agree. If it's not sealed (which it can't be if it's not vacuum packed yet) then it's a risk anyway, even if the exterior is 100% clean (which it won't be.) Tbh I'd be looking at segregating the whole process not just buying a separate vacuum sealer but honestly, this process is dangerous. DON'T DO IT! There is no risk assessment which will make this safe because there have been outbreaks associated with this precise practice so any risk assessment which allows this will be ignoring the previous outbreak and so, will be invalid.

[Charles.C]

Dear tisher,

This was the conclusion to the case previously referred by GMO -

http://news.bbc.co.u...les/6990184.stm

I suggest you re-examine GMO's previous link with great care. One key word is "separated" and for RTE/NRTE products, that typically means by a physical barrier(s).

Rgds / Charles.C

[GMO]

Great link. I think this quote sums it up:

"He was jailed for a year for food safety offences after Cardiff Crown Court heard that a vacuum-packing machine, "wrongly used" for both raw and cooked meats, was the source of contaminated meat to schools."

[foodsafetyboy]

If I can do a risk assessment on a common area that RTE and NRTE product flows through why can I not do a risk assessment on a common machine/area that is used for RTE/NRTE product?

Hi Tisher,

Of course you can, but the thing is, it is always best to segregate NRTE from RTE to avoid chances of cross contamination. Of course a cleaning procedure can be used as a control point to nullify contamination of RTE from machines used for NRTE but it has to have the correct contact time and chemical concentration and of we cannot predict the mentality of the workers.
Why complicate things if segregation of the two is possible.

Just saying.

Regards,
FSB

[BarrieT]

I agree with GMO's screams of panic......it would not be permitted in the UK under the new official guidance (but I can't comment regarding Canada's requirements).

[GMO]

Unless on crossing the Atlantic E. Coli O147: H7 loses it's potency?

I'm not sure whether you said earlier on in the process whether you're working to a standard? I'm certain BRC wouldn't allow this anymore, not sure about other ones. Our governmental environmental health officers would at least raise an improvement notice. Certainly anyone familiar with the Welsh case would be horrified but I suppose you might be lucky (or unlucky) that it's unlikely in Canada?

Personally I couldn't live with the moral cost of this. A butcher who did the exact same process ended up in prison (for an inconsequential amount of time in my view) because his actions killed a child. I really don't understand why that wouldn't make any food safety professional think "this is more important than anything else I've ever done to make sure we don't introduce the same risk". Perhaps it's just because I have a toddler and I am a lot less tolerant but if you can't make your managers understand the risks here, what are you doing in that company? Are you prepared to harm or kill someone to keep your job? Go to gaol?

You might think I'm going over the top but when your process is so similar to something which killed a child, why on earth would you want to "risk assess it away"? It is your job as a food safety professional to get the big boots on sometimes and say NO!

Sorry, just can't be rational on this one.

If it were me and the boss didn't listen to me, I would ensure I had some written evidence of my concerns and go straight to the EHO and be a whistleblower.

[helen89]

Hi,

RTE and NRTE food under Canadian law must be seperated by physical barrier.

E. coil is but one of the things that can kill.

Please refer to the federal regulations for your product if you sell outside of your provience: Canadian Food Inspection Agency or the guidence documents for your provience.

Risk assessment RTE/NRTE product flow ....re: the common hall way to seperate coolers should of resulted in scheduling product flow through hallway at seperate times of the day with all RTE being moved first to avoid any chance of NRTE transfer to RTE.

Your original HACCP assessment should of identified the use of the vac packer for RTE and NRTE as a significant hazard.

I suggest a complete reveiw of your hazards by a third party auditor.

[Jewl578]

I am in the same predicament,

We do not have the space to separate RTE from NRTE in the processing area. and I am trying to find out if BRC allows this to take place.

We would like to run heat treated products and ready to eat prodcuts but not at the same time, with complete sanitation cleanups in between.

We are BRC RTE Certified, but have the opportunity to run a NRTE product with or without fully cooked meat in it.

Does anyone know if this is allowed by BRC?

 

Thanks!