Code of Practice for Minimally Processed Ready-to-Eat Fruit and Vegetables
Part III Processing Controls

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1. Product Formulation

1.1 Specifications

Written specifications for all components, including raw fruits and vegetables, any added ingredients, packaging materials and gases that are necessary for the process and packaging of the finished product should be in place.

Raw fresh fruit and vegetables should be sourced from suppliers that have adopted good agricultural practices and provide evidence that the product was grown, stored and transported to the facility according to written specifications. Refer to Part I Good Agricultural Practices.

Written specifications should be in place for ingredients and components that identify criteria essential for the process and product safety (e.g., allergens, permeability of packaging materials, and grade of gases appropriate with food contact use).

Specifications should include a provision for compliance with the Food and Drugs Act and Regulations, specifically: food additives, if present, must meet the requirements; and packaging materials must be intended for direct food contact.

1.2 Product Formula

Current written formulae should be available for each multi-component product processed into fresh-cut.

Formulae should be followed to produce a consistent and safe final product and to avoid introduction of potential hazards (e.g., adding unlisted ingredients which could cause allergic reactions).

  • Current, written formulae for multi-component products should be available to production employees.
  • The formulae should contain all details of the formulation such as the identification and amount of ingredients, including food additives.
  • If food additives are used their levels must conform to the provisions of the Food and Drugs Act and Regulations.

2. Incoming Material Control

2.1 Incoming Materials

Incoming produce, ingredients, packaging materials and gases should be controlled to minimize microbial, chemical and physical hazards and to prevent mislabelling or misrepresenting of final product. For incoming ingredients that are likely to impact on the safety of finished products, one of the following programs should be in place:

Periodic Evaluation of Incoming Materials:

  • A certificate of analysis should accompany each incoming lot.
  • At a scheduled frequency appropriate to the risk, representative samples should be taken to verify the accuracy of the certificate of analysis.
  • Records of supplier adherence to specifications for each ingredient should be maintained (e.g., analytical results).

Lot Inspection

  • Incoming lots should be inspected and sampled according to a pre-determined sampling plan and evaluated for adherence to specifications.

Supplier Verification

Records should be maintained to demonstrate adequate knowledge of the supplier's practices and process (e.g., agricultural practices on farm, process flow, etc.)

  • Periodic monitoring and auditing of suppliers should be conducted to verify adherence to specifications e.g. validate the status of the supplier adherence to on-farm food safety program.

2.2 Incoming Material Control Records

Records should be maintained to demonstrate the adequacy of incoming material controls.

These records will allow verification of the processor's control over microbial, physical and chemical hazards associated with incoming materials.

  • Appropriate records should reflect the established incoming ingredient control program (e.g., analytical results, history of adherence to specification, audit reports etc.).

3. Preprocessing and Processing

All critical processing factors should be controlled to minimize risks associated with the product. Raw fruit and vegetables should be inspected, sorted, trimmed, washed and disinfected, as appropriate, to prevent contamination of the finished product.

3.1 Inspection, Sorting, Trimming and First Wash

During preparation of fruits or vegetables for processing, microbial, chemical and physical hazards should be minimised by conducting the following:

  • Visual inspection and removal of decomposed product, extraneous matter, produce contaminated by fuels, (e.g., diesel, gasoline), machine grease or oil.
  • Removal of dirt and washing product.
  • Metal detection using magnets or metal detectors.
  • Sorting /cleaning by gravity, air or water.

3.2 Peeling, Slicing, Chopping, Cutting, and Shredding

Procedures should be in place to minimize contamination with physical (metal) and microbial contaminants during peeling, slicing, chopping, cutting or shredding processes.

3.3 Washing

Washing cut produce with potable water reduces microbial contamination. In addition, it removes some of the cellular fluids released during the cutting process thereby reducing the level of available nutrients for microbial growth.

  • Cut fruit or vegetables should be washed in potable water that meets or exceeds the Guidelines for Canadian Drinking Water Quality.
  • Water should be replaced at a sufficient frequency to prevent the build-up of organic material and prevent spreading microbial contaminants over produce.

3.4 Antimicrobial Treatment

Antimicrobial treatments should be used to minimize or reduce contamination of finished products.

3.4.1 Chlorinated Wash Water

Chlorine may be added to wash water to reduce microbial contamination on produce. After the chlorination treatment, excess chlorine should be removed from the produce.

  • The chlorine concentration, pH, temperature of the wash water and contact time on the fruit or vegetables should be monitored and controlled.
  • The manufacturer's recommended methods for mixing and levels of chlorine in wash water should be used. Otherwise, the recommended concentrations for chlorinated wash water are between 100 and 150 ppm of total chlorine or between 2 to 7 ppm of free residual chlorine after contact. The pH of the water should be between 6.0 and 7.0. The contact time is dependent upon the product and the chlorine concentration but ideally should not exceed 5 minutes.
  • Excess chlorinated wash water should be removed from the produce (e.g., by rinsing with potable water, and if appropriate with centrifugal drier, etc.)

3.4.2 Other Antimicrobial Treatments

Antimicrobial treatments other than chlorination should be evaluated for their safety and efficacy by the Food Directorate of the Health Products and Food Branch, Health Canada.

  • The antimicrobial treatments must comply with the Food and Drugs Act and Regulations.
  • The use of antimicrobial treatments should be monitored and controlled.

3.5 Adherence to Product Formulation

Processing should be controlled to ensure that each multi-component product is produced in accordance with its formula.

Adherences to product formulae ensure that products are consistent and prevent the addition of ingredients not listed on the label that may elicit an adverse reaction in sensitive individuals and ensures that ingredients essential to product safety are added.

  • Controls should be in place to ensure that each product contains only the ingredients listed in the formula and on the product label.
  • Controls should be in place to ensure that food additives, if present, are used within allowable levels, accurately measured and adequately blended for homogeneity.
  • Controls should be in place to prevent the presence of undeclared ingredients that may elicit an adverse reaction in sensitive individuals. Potential areas that may require stricter controls include:
  • misdirected ingredients;
  • use of reworked product;
  • carryover from equipment after product changeovers;
  • substitution of ingredients.

3.6 Product Temperature During Processing

Product temperature should be controlled during processing to minimize the growth of pathogenic microorganisms.

Numerous factors may affect product temperature during processing including: variations in the temperature of incoming produce; fluctuations in ambient temperature; and changes in wash water temperature. If the product is packaged at elevated temperature, there may be an unacceptable time lag before the product reaches refrigeration temperature. This could result in growth of microbial pathogens to unacceptable levels. The processing should be controlled to ensure that product temperature is reduced to refrigeration temperature (4°C or less) within an acceptable time frame.

The processor should demonstrate the control of product temperature through one of the following programs or equivalent:

Cold Chain Concept

  • Produce temperature should be maintained at, or reduced to, 4°C or less prior to the start of processing.
  • The air temperature in the rooms where fresh produce is processed should not exceed 4°C. Wash solutions should be maintained at 4°C or less. Any other treatments that are part of the process should not cause the temperature of the produce to increase above 4°C.
  • At all times, finished product temperature should be at 4°C or less.

3.7 Product Processing Records

Records that reflect the control of critical processing factors should be available upon request.

Records will allow verification of the process and product composition and should be available to demonstrate the following:

  • Adequate control of critical process and composition such as: chlorine concentration, pH, contact time, use of other antimicrobial treatments.
  • Control of product temperature during processing.
  • Noted deviations during the process and corrective actions.

4. Packaging

4.1 Packaging and Containers

Packaging and product handling should be controlled to prevent product contamination.

An effective system should be in place to prevent the use of contaminated, damaged or defective containers that come in contact with produce. The controls that are in place should be verified through periodic checks.

  • Containers should be used only for their intended purpose.
  • Packaging should be handled and transferred in a manner to minimize damage and contamination. There should be controls in place for receiving, storage and conveying.
  • Packaging should be examined for damage and contamination before use.
  • Where containers are re-used, the processor should have in place an effective cleaning and sanitizing system, before use.

4.2 Critical Packaging Factors

Container filling and sealing should be controlled to meet the criteria outlined in the establishment's process design.

Deviation from the packaging criteria could result in contamination or growth of microbial pathogens.

  • All critical packaging factors should be identified and controlled, such as: bag or container composition; gas mixture; flushing time; and sealing of container.
  • Controls should be in place to identify and correct situations where container damage could occur.
  • Packaging records should be available to demonstrate adequate control of critical packaging factors.

5. Container Coding and Labelling

5.1 Product Identification

Each packaged food product should be marked to allow the identification of product in the event of a recall.

  • Each prepackaged food product should be permanently and legibly marked on the label, the package or container with the following product information: the brand, type of product, the responsible party for the production or marketing of the product; ingredient list, if applicable.
  • A code, from which the production date can be determined, should be permanently and legibly marked on the label, the package or container. The "best before" date may form part of this code.
  • Code marks and their meaning should be available. Where used, case codes (master containers) should be legible and should correspond to the identifying marks on the product within.

5.2 Label Accuracy

Label information should be complete and accurately represents the product. The label must meet the requirements of the Food and Drugs Act and Regulations and the Consumer and Packaging and Labelling Act and Regulations.

Controls should be in place to prevent mislabelling. Accurate labels inform and protect individuals allergic or sensitive to certain foods or with specific dietary needs.

  • Procedures should be in place to ensure that labels accurately reflect product formulation and composition. These controls should include:
  • Effective separation of product types during changeovers.
  • Separation of product labels or pre-labelled packaging during processing activities and storage.
  • On-line checks to ensure that products are correctly labelled.

5.3 Labelling – Storage Temperature

All finished products should be labelled with the statement: "Keep Refrigerated".

Products should be kept at refrigeration temperature during storage, transportation and display for sale to minimize the potential for growth of microbial pathogens. Proper labelling is required to ensure that all persons handling the product are aware of the storage temperature requirement. "Keep Refrigerated" as defined by the Food and Drug Regulations means kept at 4°C.

6. Deviations and Corrective Action

6.1 Deviation Procedures

Procedures should be in place to identify, isolate and evaluate products when critical limits are exceeded or when other defects occur which could affect product safety.

Identification of Deviation

  • System should be in place to identify deviations when they occur.

Isolation of Affected Product

  • Effective procedures should be in place to isolate, clearly mark and control all products produced during the deviation period.
  • All affected product should be isolated from the point where the process was last in control and be clearly marked (e.g., tags firmly attached with information such as: reason for hold; amount of product; person in charge; date; etc.).
  • Affected product should be controlled until its final disposition or until other actions are required following evaluation and assessment.

Evaluation of Affected Product:

  • Product evaluation should be conducted by a qualified person and should adequately assess potential health hazards. The evaluation should include adequate sampling to identify the extent of the problem; appropriate tests; etc.
  • The product should not be released unless the evaluation determines that no health hazard exists.
  • Actions on affected product (e.g., sorting, re-processing, and disposal) should be conducted in an appropriate manner by adequately trained personnel.

6.2 Corrective Action

Effective corrective actions should be implemented to prevent the recurrence of deviations.

Corrective action procedures should be in place in order to determine the cause of the problem, take action to prevent a recurrence and verify with monitoring and reassessment to ensure the efficiency of the actions. The corrective action procedures should include:

  • An investigation to determine the cause of the deviation.
  • Effective measures to prevent recurrence of the deviation.
  • Verification of the effectiveness of the corrective actions taken.

6.3 Deviation and Corrective Action Records

Records should be available to demonstrate controls of deviations and the effectiveness of corrective actions.

Maintaining complete and accurate records will allow verification of the adequacy of the processor's control of deviations and the implementation of effective corrective action procedures.

Deviation/Hold

  • Deviation records should include information such as: product and code; date when the product was manufactured, held, released or destroyed; description of deviation and reasons for the hold; amount of product held; results of evaluation (e.g., amount analyzed, number and nature of defects); disposition of product (e.g., amount sorted, destroyed); name of person responsible for hold and evaluation; and if required, signed authorization for disposition.

Corrective Action

  • Corrective action records should include information such as: cause of deviation identified; corrective action taken to correct the deviation; follow-up/assessment of effectiveness of corrective action; date corrective action was taken and verified; and name of person responsible.

7. Verification of Product Safety

7.1 Verification Procedures

Supplementary methods should be used to evaluate and verify the effectiveness of controls affecting food safety.

The purpose of verification is to determine the effectiveness of processing controls in preventing health hazards and to indicate areas where improvements are required.

  • Qualified individuals responsible for verification should be identified.
  • The verification frequency and methods should be appropriate to the hazards associated with the product and process.
  • Methods of verification should include: sampling and analyses of in-process and finished product for the appropriate chemical or microbial hazard (e.g., Listeria monocytogenes, Salmonella spp., etc.); verification of the concentration of antimicrobial treatment, pH and/or temperature of wash water; independent external or internal audits; analyses of consumer complaints; trends; and audits of suppliers or customers (e.g., verification if transportation and storage temperatures are being followed as per specifications).

7.2 Verification Records

Records should be available to demonstrate the effectiveness of verification procedures.

  • Verification records should include methods of verification, date, individuals responsible, results, findings, conclusions, and corrective actions taken.

8. Complaint Handling

8.1 Product Complaints

An effective system for handling and investigating complaints should be in place.

Customer and/or consumer complaints are an important indicator of possible deficiencies of processing controls and/or the distribution handling procedures.

  • Qualified individual responsible for receiving, recording, evaluating, categorizing and/or investigating complaints should be identified.
  • Complaints should be accurately categorized according to the risks.
  • Safety-related complaints should be forwarded immediately to the appropriate personnel for action.
  • Safety-related complaints should be investigated by appropriately trained technical personnel.
  • Examination of the complainant's specimen, retail product or other product of the same code should be part of the investigation into food safety related complaints.
  • The depth of the investigation should be appropriate to the risk and similar complaint trends.
  • Appropriate corrective actions should be taken for deviations identified during the investigation.

8.2 Complaint Records

Records of product complaints, investigation findings and actions taken should be available upon request.

Consumer Information

  • Consumer information records should include information such as: the name, address, telephone number, and date received; the details of complaint and/or illness; the product name, code and size; and the retail outlet where the product was purchased.

Investigation

  • Investigation records should include information such as: the name of the person responsible for the investigation; the action taken on products as a result of the investigation; and the corrective action taken.
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