Risk assessment sorting/cutting fresh ginger

Hello,

I'm a little bit blocked with doing a risk assessment for a completely new kind of activity that we have to do now. We are (re)packing fresh fruit and vegetables. In case the quality is bad we sort out the bad ones: this means that we remove that one piece of blueberry, strawberry, apple, cucumber which is molded, dry or soft. One of our clients (the actual owner of the product) is handling fresh ginger. He receives 20 pallets with ginger of not so good quality. This means that the rhizomes are partly shrivelled  or with mould. In order to reduce his loss, he wants that we remove the bad part by cutting out the part which is shriveled/molded.   

Would you consider this product as being a pre-cut (or freshly cut) vegetable? It is not that we are slicing it in small pieces, we only remove one "finger" or we cut the already cut end of the rhizome. As a post harvest treatment the grower also has to remove the stem/leaves from the rhizome by cutting it off, so we are sometimes doing the same operation that he has already done before. After this sorting operation the ginger is supposed to go back in the same box from where it came. The end customer is still supposed to peel and cut the ginger before using it. If you consider it as a pre-cut vegetable, then do we need to determine a "best before date" for it and make microbiology analyses to see that there are no infections with Listeria/Escherichia?

In case you consider that this is not yet a pre-cut vegetable, what would you do for the risk assessment? I tried to do some shelf life tests and see what will happen with the ginger in time: the bigger the cut, the bigger the weight loss will be and the easier the product will dry. Also after 3 weeks mould will appear on the cut surface, just like on the ginger that we receive.         

I would consider it a fresh cut vegetable. If you were just culling bad ones from the whole lot and discarding them that would be the same as what you do with soft fruits

since you are CUTTING, you could introduce new hazards 

Post harvest process' that the grower undertakes are simply to get the product to you.......on farm activities are handled differently that in a pack house. 

You need to ensure employees are following stricter GMPs (like chlorine dips for knives, handwashing, inspection of knives for missing pieces)

If you are able to simply BREAK the bad piece off then you are simply culling the bad ones

and since the ginger is cut and mixed with moldy ones, you've got the additional hazard of reintroducing mold back to the fresh cut surface and thus recontaminating your product

it really sounds like it ought to be a 2 step process.............remove all rhizomes that cannot be salvaged and remove all that do not require trimming................trim all reminders