6 replies to this topic

[lillabec]

Hi everyone, we have a somewhat unique CCP here, which is the disposition of E. Coli O157:H7 and/or STEC6 positive beef trim. Positive trim gets locked away until the rendering company arrives, in which case someone from QA management accompanies the bin of trim to the rendering truck.

The control measure is the program for the disposition of the positive material.

The critical limit is the verification of the end user - whether it be the rendering company or a cooker.

I know it's weird, but it is what it is...

My question is, to monitor this CCP, should we be documenting the results every time we get them back, whether positive or negative? 

Or should we be documenting the disposition/end user verification of only the positive lots? 

Should we be "monitoring" the positive lots in any ways other than just documenting the end user verification?

 

This is a newer facility with various forms created when trying to start up and now that we're more established, I'd like to find a more understandable way of monitoring this...

 

Additionally, like a pre-shipment review form where you release the product to shipping involving their signature, is it required to have a form where you release the product to operations (we use all of our in-house trim, nothing is shipped out) involving their signature? I haven't been able to find anything requiring this. I would think releasing it from hold and communicating that to them would be their notification that it is good to be used.

[kconf]

Your disposition practice seems ok - end user verification. As long as it no longer remains at your site and you can tell what went where, when, you are good. 

 

What do you do with the good (negative) beef trims? Do you keep positive and negative segregated? 

[lillabec]

Your disposition practice seems ok - end user verification. As long as it no longer remains at your site and you can tell what went where, when, you are good. 

 

What do you do with the good (negative) beef trims? Do you keep positive and negative segregated? 

 

Yes, positives are locked in a cage, whereas negatives are released from hold and moved to the ready-to-use trim location.

[kconf]

Why are they both put on hold? Waiting for results? 

[lillabec]

Why are they both put on hold? Waiting for results? 

 

Yes all the trim gets put on hold until results are received

[kconf]

You should be documenting both positive and negative results. 

[G M]

...

My question is, to monitor this CCP, should we be documenting the results every time we get them back, whether positive or negative? 

...

 

 

Yes.  It is essentially like other pass/fail checks, and you should be recording all the ones passing too.

 

 

...

Additionally, like a pre-shipment review form where you release the product to shipping involving their signature, is it required to have a form where you release the product to operations (we use all of our in-house trim, nothing is shipped out) involving their signature? I haven't been able to find anything requiring this. I would think releasing it from hold and communicating that to them would be their notification that it is good to be used.

 

If it's a CCP this would fall under the set of items being reviewed for USDAs mandatory preshipment review.  They are reviewing, among other things, that the disposition of positive and negative batches was appropriate.

 

It doesn't have to be a separate form.  Our daily CCP records have at the bottom of the page a line for a DO/RR reviewer, as well as for a preshipment reviewer's signature.