Greetings all, I hope you guys can help/offer some advice here.
I have worked for a company that processes smoked fish and each year the EHO shows up and raises new issues with my HACCP plans.
I have worked within the Food industry for years and have implemented and achieved BRC AA on a few sites with no issues, however this EHO is driving me nutts.
I have conducted a risk assessment and having identified Listeria as being hazard i have created a CCP for a listercidal kill step during the cooking phase. and have undertaken many shelf life tests from day 0 to day 30 (declared shelf life 21 days) and have never had any issues except for the occasional yest detected towards the end of life.
The EHO has said that i need to determine the controlling factors for listeria. against the EC regs with regards to Absent from...
As far as im concerned i have in that i have
1) identified and have procedures for cleaning and sanitation and all the other PRP's which refer to pathogens of concern.
2) Included within my risk assessments Pathogens of concern and referenced said PRP's at relevant process steps and the kill step as a CCP with all corrective actions etc..
3) i have validated the the controls
4) I am currently verification the controls through taking micro swabs and product sampling.
I believe i have covered everything which is why im stumped.
Personally feel she has a bee in her bonnet with our site... shes been many times before and had no issues relating to this. and now suddenly its an issue.
Whats more is im asked for documents, which i give and then get quized on info thats clearly in them showing she has not even read them.
Any help appreciated.