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Pathogen testing paperwork

Started by , Jan 05 2021 03:30 PM
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This is something I've been bouncing around my head, so I thought maybe some input from you fine folks may help.   We're a dry mix manufacturer. I path test environmental stuff, finished product, and vendors against their spec sheets.In our process there's a few sub-assemblies that we make out of 2-3 raw ingredients, then use them as ingredients. In my paperwork, it doesn't really cover testing of these. It's not a finished product so it's not bagged and sent  to customers.  Nor is it a raw ingredient that is stand alone, and I have no spec to test against.  So where should I put this?  I'm trying to make it as painless as possible paperwork wise. It seems to me I should put it in raw ingredients/vendor testing, and write in some special exceptions, set limits or use my current finished limits? Any input is welcome guys, thanks!

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????  Not a finished good and not raw ingredient once blended???  

 

Need a bit more process flow detail to sort this one out

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????  Not a finished good and not raw ingredient once blended???  

 

Need a bit more process flow detail to sort this one out

Ha, exactly!   It goes through our blending process like any other thing we make, then goes into 50 pound bags to be used as a sub-assembly ingredient in formulations later.   So for instance we have one that is salt, flour, liquid pap mixed together, called papmix when it's mixed.   The blend of that is used as an ingredient in many other formulations.  

So I could call it a finished good since it goes through the process, but I'd need to redefine in all my paperwork what constitutes a finished good.   Same goes for the raw ingredient, because when I wrote all the paperwork years ago raw ingredient testing was written as a check on vendors, and this isn't from a vendor.  

I'm thinking it'll be easiest to make some changes to the vendor testing, call it 'vendor/ingredient' testing, and write it in there.   I don't really want to do it as a finished good, because in the event of a bad test there's a litany of steps to take dictated in the paperwork that I don't think I'd need or want to do.  

It sounds like this product is what my facility would classify as an "Intermediate".  Instead of lumping it under your exiting sections that aren't entirely applicable, why not create a new section for Intermediates?

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It sounds like this product is what my facility would classify as an "Intermediate".  Instead of lumping it under your exiting sections that aren't entirely applicable, why not create a new section for Intermediates?

Yeah, that's as good a name as any, and I think you're feeling my pain.   Is that how you handle it?   It definitely makes sense to have it's own set of WI's and paperwork.   Where do you have your limits set?   I was thinking the same as finished product should be fine....

You shouldn't (in theory) need to test it again. Your process should prevent it from becoming contaminated--assuming you are testing all of your finished goods?  The papmix ingredients arrive from an approved vendor with a CoA that is reviewed prior to use-correct?

You shouldn't (in theory) need to test it again. Your process should prevent it from becoming contaminated--assuming you are testing all of your finished goods?  The papmix ingredients arrive from an approved vendor with a CoA that is reviewed prior to use-correct?

I'd have to disagree with that.   If that's the line of thinking, why am I testing finished product?   

thats a great question to ask yourself????

 

Do your customers demand a CoA?  HACCP is supposed to eliminate the need to test FG; that's the entire idea, so that you'd never have to worry about product entering the market place that isn't fit for consumption

 

FG testing done as annual verifications to validate that the current process isn't contaminating your product


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