Sanitation Validation for extended run times.

We just completed a corporate audit and we received a non-conformance for not having a validation study completed for our extended run time.  Since I have been in my current food safety position for 9 years we have always run the same number of days, we run a 21 day cycle.  Now I need to do a validation study.  Would it be simple enough to use our micro testing results of our finished product that we test every four hours as an effective validation?  Or should I also include some micro testing of the production line?  We do micro testing after each clean-up and that is always quite good.  Our product testing also has very good results.  We produce a NRTE product that must be reconstituted in an oven (360F) or fryer at (360F) by the end user.

Jim.(Peeved in Canada)

:shutup:  :shutup:  :shutup:

Sorry Jim, if you've never done a validation study then you kind of need one. Just because it wasn't caught in the past doesn't mean it's not a requirement for you. The good news is that I think you're right and that if you consolidate all of your data from the past 9 years and organize it, you can probably use your existing data to establish a validation for the interval.

FSIS has an awesome document for how to validate/verify extended run sanitation intervals here: https://www.fsis.usd...pdf?MOD=AJPERES

If you collect your data and borrow some of the language from that guide and use it to validate your justification, you may be good to go. Otherwise just do a new study, consolidate the data, and demonstrate that the interval is appropriate.