An interesting question itay.sh and lots of people just accept these figures. You might be interested to see where they come from, I certainly was when I looked into it approx 4 years ago when we had the same issue arise.
There is a very useful table in the CFA "best practice guidelines for the production of chilled foods" on p12. If you don't have a copy, the reference they took the information from was Food Microbiology 1989 6 p251-259 and also technical memorandum No. 523 from the CCFRA (although the chilled food best practice document is a useful one so it might be easier to buy it.)
Your value of 72 degrees 15 seconds is, IMO wrong. Could it have been a typo at some point in the history of your
HACCP plan? According to the figures in this table (and I've seen these repeated regularly in other
HACCP plans), 72 degrees should be held for
1 minute and 5 seconds to achieve a 6 log reduction in vegetative
Listeria. If you can only hold for 15, you should heat to 77 degrees.
IMO all of that literature stuff should always be backed up by some practical testing as part of that validation. If you go for lower temperature / time combos though I would suggest you need full validation of that temperature and time in your product type.
In this table, they state, and I agree that you could use these figures to control other vegetative pathogens; however, this does not control spore forming pathogens and will not control heat stable toxins.
I think you should consider whether
Clostridium perfringens is a genuine risk in your product as it won't currently be controlled and to be honest I'd doubt it would be an issue. I would also consider whether
S. aureus could be controlled through GMP routes as any toxin formation before this heat process would not be distroyed, I would also consider that
B. cereus is a hazard and it's not a bacterium you will ever kill with your process but you should ensure your cooling time is sufficiently short to prevent toxin production during that time or water activity is sufficiently low in the product to prevent any issues.