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The current Pathogen
Testing Protocol being instituted by the FSIS for RTE product
processing plants will be setting minefields for processors to nimbly
maneuver without finding themselves blown apart by a recall, a plant
closure and the resulting costs that mushroom around these
incidents. There are many processors who have been reluctant
to test for Listeria monocytogenes because of the
ramifications of having a positive sample. One means to avert
the problem is to test for Listeria at the genus
and not to specie level. This has been, and will probably
will continue to be a common practice, especially for environmental
samples. This new FSIS directive eliminates the reluctance to
test by regulation.
The
requirement for documentation of sample sites, sample collection,
sample results and after-action results for the sample sites is a key
to developing and maintaining a comprehensive science-based pathogen
sampling program that will meet FSIS requirements as well as assist in
providing a foodsafe product for the customer. Although this
can be done by performing the steps and documenting on paper or even
creating “islands of information” with computer
aided testing and monitoring equipment, the major problem of
non-compliance because of missing data or “pencil
data” can arise and cause the most unwanted
problems. The legend of a problem arising and the incessant
search of records to find the one page with the one cell that
wasn’t completed probably is more true than most people
realize because virtually everyone can attest to it. Of
course, the reason that you are searching for that one piece of data
for the problem that arose is because it was missing in the first place.
The Sentry9000
system is designed to manage the data collection from control points on
the processing floor. It provides the security for insuring
that missed data does not occur and if it does, the personnel to
correct the problem are alerted. You don’t have to
wait for a customer or regulatory agency to alert you.
There are two
modules for Sentry9000 that provide the regimentation and
documentation needed to successfully manage this sensitive
program. They are Sentry LIMS, the Laboratory Information
Management System module, and Sentry ARMS, the Allergenic Response
Management System.
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Sentry
LIMS keeps track of testing demand for ingredients,
in-process, finished product and environmental samples. It
controls Hold and Release for ingredients and products through test
designation and test results. It can provide action steps for
sanitation and production personnel when environmental sample
results dictate. The Sentry LIMS system can be adapted to fit
small to large plants and can interact with third-party laboratories to
have data entered directly into the Sentry LIMS as it is input at their
site. The system is designed to be the watchdog for sample
collection, the reviewer for sample results and the enforcer for action
steps resulting from sample testing.
Sentry ARMS was designed to document the
sanitation steps for plants that produce products with and without
allergens. The system is based on cleaning protocol and
redundant, step-up verification. It is used to prevent
processing lines from operating without full compliance to the
plant’s allergen control standard operating procedures.
The Sentry
ARMS module can be easily adapted to interact with the Sentry LIMS
program to provide instruction and documentation with verification for
Corrective Action steps, Pre-Op Inspections and after action steps for
laboratory analyses to comply with FSIS directives for positive
pathogen tests and for indicator positive tests. The
interaction provides the compliance trail for verification and the
digital media provides the documentation required. Sentry
ARMS is a multi-functional module that can be used not only for
allergen control and pathogen control, but provides documentation and
verification for basic Sanitation SOP’s, Kosher Certification and ISO programs.
The Sentry9000
Information Management System is a multi-faceted system capable of
providing automatic data management and implementation of tasks when
results are outside of established limits.
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