quirements, whether expressed as an
FSO or as a microbiological requirement, were considered, then this would
need to be translated upstream in a different manner. For this example, it is
assumed that no change in the microbiological flora is occurring during distribution to the consumer. For manufacturer
A, manufacturing product X through
the application of dry mixing technologies, that is, without an additional kill
step, would mean that the PO1 would
need to be equivalent to the established
FSO1, hence the microbiological specifications would need to be equivalent
and therefore be reflected in the microbiological specification of the raw
materials.
In the case of manufacturer B manufacturing products Y and Z with different technologies (e.g., wet mixing
including a kill step), in principle, different POs or microbiological specifications would be derived. In the case of
the dry mixing process, the requirements
would also be equivalent and translated
into microbiological specifications. In
the case of the wet mixing process, the
requirements of the finished products
would of course need to be equivalent to
those of the FSO/microbiological criteria. However, in this case, the requirements for the raw materials could be
adjusted based on the effect of the heat
treatment (control measure) and hence
be less strict. This would mean that, in
the case of DMI, the POs and microbiological criteria at the step of the raw material suppliers would need to be
equivalent to those “downstream,” while
the POs and microbiological criteria for
WMI would be less stringent.
In the case of DMI, the interactions
between the supplier and the user of the
raw materials would certainly go beyond
the simple establishment of microbiological specifications and the testing of samples. It would certainly also include,
from the user, a review and assessment
on the type and effectiveness of hygiene
control measures as implemented by the
supplier.
It is therefore clear that requirements
such as microbiological specifications for
several applications may differ. Milk
powder used, for example, to manufac-
ture chocolate, ice cream, infant for-
mula, beverages for adults, ultra-high
temperature products, etc. would need
to fulfill different requirements. The way
to manage and the degree of stringency
of control measures as well as verifica-
tion measures may therefore be different
and must be appropriate for their
specific purpose.
