Devil Lettuce
Well-Known Member
I will respectfully disagree with this. I don't think that this was a case of bacterial counts just magically rising over a short period of time due to choosing not to irradiate. This batch was only a few weeks old at most, it's not like it was past its expiry date. Based on the information provided, I am guessing that the problem had to do with improper product handing in the shipping stages. This is what I think likely happened:The Lift piece makes it seem like the following:
1. initial test results are within specification = release it.
2. the retest, which is likely being done to assess stability and validate storage conditions, shows the counts have crept up during storage.
Remember that the MMPR does not require an expiration date but HC will probably enforce stability testing for GPP, which is normal. You are expected to track stability.
This is why you irradiate . It is not done so you pass the initial release specification; no GXP is going to let you make dirty stuff, no matter what you HC conspiracy theorists think. Irradiation "shines" through by making sure nothing pops up when you store it until a user pops it open, exposing it to live bugs/spores. You can dig into one of the old Hazekamp articles to see how much higher the café counts were.
1. initial test results are within specification = release it.
2. product placed in plastic or glass containers for storage
3. orders for product start to come in and are filled
4. employee handling orders causes contamination by not following SOPs (not washing hands, was sick, dirty area)
5. more orders of product are shipped
6. a problem was identified (looking at video tape, self-audit) and more tests were run on the batch and were positive for bacterial count
7. voluntary recall
From memory, I believe 54 orders were affected and recalled. That's 54 times that bin was opened and reached into, probably by multiple employees. If proper SOPs were not in place, or were not being followed, it's not hard to imagine a contamination occurring after the 3rd party testing came back. It would only take one employee to not wash up or change their gloves to contaminate the remainder of the batch. As it would be impossible to determine at which point the contamination occurred to bring counts above acceptable limits, all product had to be recalled.
No amount of irradiation will make up for poor product handling practices, and an ounce of prevention is worth a pound of terpenes destroyed and unnatural compounds left behind
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