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Zeeshan

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Posted 14 January 2012 - 07:54 AM

Dear forum members.

I need your help to categorize my five production zones as LOW RISK, HIGH RISK and HIGH CARE according to guidelines of BRC issue 6.

1- Meat Shop: receive fozen or fresh meat from Raw Material Store, thawing, cutting, sorting and supplying to Service Line.
2- Vegetable Shop: Receive chilled or fresh vegetables from Raw Material Store, washing, sorting, cutting and supplying to Service Line.
3- Service Line: Receive meat and vegetable from respective shops and keep them at appropriate separate storage areas. Issue material to Cooking as per recipe.
4- Cooking: Receive material from Service Line as per recipe. Issue cooked material to Filling and Sealing.
5- Filling and Sealing: Receive cooked product from Cooking, filling in the retort pouch and sealing. Liquid filling is through machine's liquid filling tank and solid is filled though manual process.

After filling and sealing, the sealed product is sent to retort process.

I would be grateful for you support.

Regards:
M.Zeeshan Zaki



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Posted 15 January 2012 - 11:02 PM

Dear Zeeshan,

If all te products are heated > 2 min > 70 oC in cooking area I would say:
Room 1, 2 and 3: low risk.
room 4: high care
room 5: high risk, unless you add uncooked garnisch. Then it is, according thedecision tree: high care.


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Madam A. D-tor

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Posted 16 January 2012 - 06:34 AM

Dear Zeeshan

i think

1 , 2 ,3 are high risk area because there chances for cross contamination like no 3 received both raw meat and raw vegetable
4 is high care because you have to care about the time and temperature of cooking without altering taste and nutrition , depends what you have required.
and 5 is low risk area , because this is finished product area and there is minimal chances for contamination until you PRP's , cGMP and hygiene not follow properly.

regards
saqib neyaz



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Posted 16 January 2012 - 07:07 AM

I disagree. Rooms 1-3 are low risk.

Room 4, it depends on where your physical barrier is. Are your staff handling raw meat and materials and then there's a physical barrier where other staff handle the cooked food? In which case it's low risk up to the barrier and high risk afterwards. High care is where not all ingredients are cooked, for example, sandwich factories where they wash salad into their clean rooms are high care. A traditional high risk factory (as this sounds) does not have a high care area. Note, if there is no physical barrier and the same members of staff are involved in handling the product when it's both raw and cooked, that will be an issue microbiologically and come audit.

Room 5 is high risk.



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Posted 16 January 2012 - 07:37 AM

in that scenario the cooking area is high care , i did not say only cooking area is high care


I disagree. Rooms 1-3 are low risk.

Room 4, it depends on where your physical barrier is. Are your staff handling raw meat and materials and then there's a physical barrier where other staff handle the cooked food? In which case it's low risk up to the barrier and high risk afterwards. High care is where not all ingredients are cooked, for example, sandwich factories where they wash salad into their clean rooms are high care. A traditional high risk factory (as this sounds) does not have a high care area. Note, if there is no physical barrier and the same members of staff are involved in handling the product when it's both raw and cooked, that will be an issue microbiologically and come audit.

Room 5 is high risk.



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Posted 16 January 2012 - 09:25 AM

in that scenario the cooking area is high care , i did not say only cooking area is high care



I appreciate that but I was just trying to clear up the confusion. BRC have been quite clear on this and this matches the chilled food association standards and definitions UK chilled food industry has been working to for decades.

High risk = an area where fully cooked products are made which is physically segregated. Everything is cooked into that area or undergoes a process which ensures they have very low micro counts. The products in this area are vulnerable to bacterial growth and are either chilled or frozen and often contain high Aw and protein contents.

High care = an area where things are segregated as much as possible (high risk style controls should be achieved where possible) but the big difference is not everything is cooked into that area but some kind of decontamination to reduce micro loadings is put in place. Typical examples include salads for sandwiches being washed into an area. You'd have to be very careful about controls in a place like this because the processes for reducing micro loading are not absolute. For example, I would be very wary of having raw meat intake in the same area as raw vegetable intake if those vegetables are simply washed into your high care room as cross contamination could result in a major issue.

Low risk area is an area where the product itself does not encourage micro growth or there's a stage later which will reduce the micro growth. That's why steps 1-3 are low risk and step 4 probably is if there are segregation controls as I indicated above.

So as I've explained it above, your answer gets it back to front. Do you see what I mean?

There is real confusion in this area from lots of people. I see a lot of non conformances due to misunderstanding in both clients and auditors. I can see why it is because logically you're thinking "raw meat contains lots of pathogens, therefore it's high risk" but the raw meat in itself isn't a risk at all because it's going to get cooked. It's only after it's cooked where nothing is going to be done to it to make it safer for the consumer to eat that it becomes high risk.

Ok, let me explain it another way.

Imagine the following. There is a food handler with Salmonella contamination on their hands.

At step 1-3 - it's not great but doesn't really matter because the food's going to get cooked later.
At step 4 it depends whether that person is handling the raw side or cooked side.
At steo 5 it could be disasterous as they would be recontaminating a cooked dish which has already gone through a heat process.

If you want to think about it in another way still, if you assign step 5 as low risk, that would mean there is only a single handwash, no captive coats, no captive footwear, utensils could come in and out of the area, no problems. The standard of build wouldn't have to be as high nor as easily cleanable. Does that make sense? Nope.


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Posted 16 January 2012 - 09:29 AM

Oh and the process of cooking is not high care. If all the ingredients are cooked, it can never be high care, it will be low risk where the ingredients go in the pan and high risk where they are taken off. Cooking should not become some kind of vague area. It should be segregated with high risk and low risk sides. Cooking ovens, sauce cooking tanks, etc, etc, are all designed to be able to achieve this.



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Posted 16 January 2012 - 11:03 AM

thanks for clear me in detail
now i m totally 100 % agreed with you

thanks alot


I appreciate that but I was just trying to clear up the confusion. BRC have been quite clear on this and this matches the chilled food association standards and definitions UK chilled food industry has been working to for decades.

High risk = an area where fully cooked products are made which is physically segregated. Everything is cooked into that area or undergoes a process which ensures they have very low micro counts. The products in this area are vulnerable to bacterial growth and are either chilled or frozen and often contain high Aw and protein contents.

High care = an area where things are segregated as much as possible (high risk style controls should be achieved where possible) but the big difference is not everything is cooked into that area but some kind of decontamination to reduce micro loadings is put in place. Typical examples include salads for sandwiches being washed into an area. You'd have to be very careful about controls in a place like this because the processes for reducing micro loading are not absolute. For example, I would be very wary of having raw meat intake in the same area as raw vegetable intake if those vegetables are simply washed into your high care room as cross contamination could result in a major issue.

Low risk area is an area where the product itself does not encourage micro growth or there's a stage later which will reduce the micro growth. That's why steps 1-3 are low risk and step 4 probably is if there are segregation controls as I indicated above.

So as I've explained it above, your answer gets it back to front. Do you see what I mean?

There is real confusion in this area from lots of people. I see a lot of non conformances due to misunderstanding in both clients and auditors. I can see why it is because logically you're thinking "raw meat contains lots of pathogens, therefore it's high risk" but the raw meat in itself isn't a risk at all because it's going to get cooked. It's only after it's cooked where nothing is going to be done to it to make it safer for the consumer to eat that it becomes high risk.

Ok, let me explain it another way.

Imagine the following. There is a food handler with Salmonella contamination on their hands.

At step 1-3 - it's not great but doesn't really matter because the food's going to get cooked later.
At step 4 it depends whether that person is handling the raw side or cooked side.
At steo 5 it could be disasterous as they would be recontaminating a cooked dish which has already gone through a heat process.

If you want to think about it in another way still, if you assign step 5 as low risk, that would mean there is only a single handwash, no captive coats, no captive footwear, utensils could come in and out of the area, no problems. The standard of build wouldn't have to be as high nor as easily cleanable. Does that make sense? Nope.



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Posted 16 January 2012 - 03:38 PM

Dear GMO,

Imagine the following. There is a food handler with Salmonella contamination on their hands.

At step 1-3 - it's not great but doesn't really matter because the food's going to get cooked later.


IMO this is faulty rather questionable logic. (added - Sorry if over-blunt, was trying to clear a blocked drainline at the same time ! :smile: )

Rgds / Charles.C

Kind Regards,

 

Charles.C


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Posted 17 January 2012 - 06:17 AM

Dear all!

Thank you Madam A. D-tor, saqibfst, GMO and Charles.C for your valuable inputs and in-depth discussion.

@ GMO: As per the logical thinking you stated (as far as I understood; Please correct me if I understood it wrong) the cooking area and filling areas (4 & 5) should be marked as High Care because the cooked and filled product is going to be retorted (commercially sterilized). The most important aspects to take care of are time and temperature control and hygiene control.

Do the members agree the most important controls which should be imposed for following marked areas?

1- Meat Shop (Low Risk): Controls ?............................... Hygiene practices
2- Vegetable Shop (Low Risk): Controls?........................Washing, Hygiene practices
3- Service Line (Low Risk): Controls?.............................Hygiene practices, Prevention of cross contamination
4-1- Cooking (High Care*): Controls?...............................Hygiene practices, Prevention of cross contamination, Time-Temperature Control.
4-2- Cooking (High Risk**): Controls?.............................. ?? (Same controls as above with high intensity ???)
5-1- Filling & Sealing (High Care*): Controls?...................Hygiene practices, Prevention of cross contamination, Time-Temperature Control.
5-2- Filling & Sealing (High Risk**): Controls?...................?? (Same controls as above with high intensity ???)

* Recommendation-1 (as recommended or perceived by some members)
** Recommendation-2 (as recommended or perceived by other members)

Regards:
M.Zeeshan Zaki



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Posted 19 January 2012 - 08:27 AM

Dear all!

Thank you Madam A. D-tor, saqibfst, GMO and Charles.C for your valuable inputs and in-depth discussion.

@ GMO: As per the logical thinking you stated (as far as I understood; Please correct me if I understood it wrong) the cooking area and filling areas (4 & 5) should be marked as High Care because the cooked and filled product is going to be retorted (commercially sterilized). The most important aspects to take care of are time and temperature control and hygiene control.

Do the members agree the most important controls which should be imposed for following marked areas?

1- Meat Shop (Low Risk): Controls ?............................... Hygiene practices
2- Vegetable Shop (Low Risk): Controls?........................Washing, Hygiene practices
3- Service Line (Low Risk): Controls?.............................Hygiene practices, Prevention of cross contamination
4-1- Cooking (High Care*): Controls?...............................Hygiene practices, Prevention of cross contamination, Time-Temperature Control.
4-2- Cooking (High Risk**): Controls?.............................. ?? (Same controls as above with high intensity ???)
5-1- Filling & Sealing (High Care*): Controls?...................Hygiene practices, Prevention of cross contamination, Time-Temperature Control.
5-2- Filling & Sealing (High Risk**): Controls?...................?? (Same controls as above with high intensity ???)

* Recommendation-1 (as recommended or perceived by some members)
** Recommendation-2 (as recommended or perceived by other members)

Regards:
M.Zeeshan Zaki


No, I don't know whether I'm misunderstanding your processes but I suspect there should be no high care area if it's a single line going from low risk to high risk. Where is your physical segregation? Where is the wall?

Charles, I was making a blunt point. Ok, you don't want a food handler carrying Salmonella anywhere in the plant but what would you do if you later found one and it was in a raw meat area? You'd send him home but not instigate a recall I suspect?


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Posted 19 January 2012 - 10:23 AM

Charles, I was making a blunt point. Ok, you don't want a food handler carrying Salmonella anywhere in the plant but what would you do if you later found one and it was in a raw meat area? You'd send him home but not instigate a recall I suspect?


Dear GMO,

Actually I was more thinking that the existence of Salmonella as you hypothesised was not at all unbelievable but no way to know how much any contamination might grow / cross-contaminate before reaching the cooking step. 6D reduction is not so useful if you have 9log of pathogens. I have previously met, and never forgotten, an analogous problem with 10ton of imported clam meat. After the routine boiling step, every sample we took was positive for salmonella, 2nd boil, 30pct positive, the 4th gave all negative. After that the filter-feeders section was permanently isolated. Canning is the same, people tend to ignore the small print under the text where it says the process is based on a certain maximum bacterial input level (I realise a Zeeshan theoretical 12D retort should flatten just about everything but the reality is not quite the same [book quoting from memory, not my field at all] :smile: )

@Zeeshan, regarding yr query about controls, this is normally given by the hazard analysis which i would hv guessed you did a long time ago already ?


Rgds / Charles.C

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Charles.C


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Posted 20 January 2012 - 02:00 AM

I believe BRC Issue 6 is merely making an attempt to close out post production residual risks against potential recontamination or cross contamination possibilities that are often ignored thus giving a false sense of confidence. A fair bit of common sense prevails here. I believe GMO had clarified the interpretation of this subject very skillfully.


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Posted 20 January 2012 - 09:24 AM

I believe BRC Issue 6 is merely making an attempt to close out post production residual risks against potential recontamination or cross contamination possibilities that are often ignored thus giving a false sense of confidence. A fair bit of common sense prevails here. I believe GMO had clarified the interpretation of this subject very skillfully.


Dear Charles,

You may be correct (didn't quite understand what you meant, sorry) however I presume the primary driving force for all this evident confusion is that BRC are determined to fully include the massive UK chilled food industry within their standard.
To illustrate the UK (chilled) involvement, can see this 2011 CFA document -

Attached File  chilled products, cfa, shelf lives.pdf   2.04MB   155 downloads

Some of the primary references to chilled RTE / non-RTE products in the other 2 parallel threads on this low/high/risk/care issue seem to be much clearer than BRC's tree etc albeit still requiring pages of explanatory examples. A typical problem with trying to condense everything together IMO.

Regarding Zeeshan's process, I am getting a little confused as to the actual details (cooking, walls etc) such as Madam A. D-tor / GMO queried earlier. I had assumed finished product is shelf stable after retorting. This seems to uniformly exclude the introduction of terms like "high risk" designations as i read section 2.3 of standard. Not criticising the previous posts/logics, simply confused. :smile: (Then again, I don't think i have ever heard of a canning operation being typically classed as low risk??)

These threads remind me of OPRP all over again. Memories ;)

Rgds / Charles.C

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Posted 20 January 2012 - 11:44 AM

Ah, now that's a question. Retorting of the food does not necessarily mean the product is shelf stable. Retorted ready meals for example are often still only chill stable. It depends on what temperature you're cooking to and what you've validated. Also I am a bit confused regarding what the product is and how it's assembled. Perhaps we could have more details?



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Posted 20 January 2012 - 01:32 PM

Some of the primary references to chilled RTE / non-RTE products in the other 2 parallel threads on this low/high/risk/care issue seem to be much clearer than BRC's tree etc albeit still requiring pages of explanatory examples.

Dear Charles,
The food processing environment, raw materials and end product risk category certainly require a large degree of concurrent risk assessment to determine risk / care categorization. While we may be able to conduct superficial perspective risk assessment, the concurrent risk assessment would be able to justify the eventual categorization. Zeeshan needs to provide the forum further data for a accurate assessment.

Cheers,
Charles Chew
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Posted 20 January 2012 - 02:53 PM

I've read through that CFA document and I completely agree with it. My understanding of high risk / high care was from the CFA originally who put a very simple and easy to understand explanation in their best practice guide for the production of chilled foods.

:off_topic: The really fascinating thing from that presentation though was the prevalence of listeria outbreaks associated with hospital sandwiches!!! I knew the manufacturers of said sandwiches had previously had some issues and I'd heard rumours regarding their lack of understanding (apologies if that's not true or a sweeping generalisation) but that does seem rather alarming!

Where are the warnings not to eat hospital sandwiches during pregnancy? :dunno:



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Posted 22 January 2012 - 05:23 AM

Dear GMO,

Regarding last few posts, please see earlier Zeeshan post #10 -

the cooked and filled product is going to be retorted (commercially sterilized)


However i nonetheless agree that it is clearly desirable that Zeeshan definitively states as to whether this product is "chilled storage" or ambient/shelf stable. Some information as to declared shelf-life would also be nice (Zeeshan? :smile: ).

Rgds / Charles.C

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Charles.C


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Posted 31 January 2012 - 06:23 PM

Dear GMO,

Regarding last few posts, please see earlier Zeeshan post #10 -



However i nonetheless agree that it is clearly desirable that Zeeshan definitively states as to whether this product is "chilled storage" or ambient/shelf stable. Some information as to declared shelf-life would also be nice (Zeeshan? :smile: ).

Rgds / Charles.C


Dear Zeeshan,

A little more input would be appreciated ? :smile:

Rgds / Charles.C

Kind Regards,

 

Charles.C


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Posted 01 February 2012 - 05:14 AM

No, I don't know whether I'm misunderstanding your processes but I suspect there should be no high care area if it's a single line going from low risk to high risk. Where is your physical segregation? Where is the wall?


Regarding Zeeshan's process, I am getting a little confused as to the actual details (cooking, walls etc) such as Madam A. D-tor / GMO queried earlier. I had assumed finished product is shelf stable after retorting. This seems to uniformly exclude the introduction of terms like "high risk" designations as i read section 2.3 of standard.


Ah, now that's a question. Retorting of the food does not necessarily mean the product is shelf stable. Retorted ready meals for example are often still only chill stable. It depends on what temperature you're cooking to and what you've validated. Also I am a bit confused regarding what the product is and how it's assembled. Perhaps we could have more details?



Dear Charles,
The food processing environment, raw materials and end product risk category certainly require a large degree of concurrent risk assessment to determine risk / care categorization. While we may be able to conduct superficial perspective risk assessment, the concurrent risk assessment would be able to justify the eventual categorization. Zeeshan needs to provide the forum further data for a accurate assessment.



Dear GMO,

Regarding last few posts, please see earlier Zeeshan post #10 -



However i nonetheless agree that it is clearly desirable that Zeeshan definitively states as to whether this product is "chilled storage" or ambient/shelf stable. Some information as to declared shelf-life would also be nice (Zeeshan? :smile: ).

Rgds / Charles.C



Dear Zeeshan,

A little more input would be appreciated ? :smile:

Rgds / Charles.C



Very very sorry for being soooo late to be here. However I am equally soooo happy that there are truly loyal so many friends here to help me.

I exactly do not know what more inputs are required for better understanding but some points are given as below:

1- My products are commercially retorted shelf-life stable ready-to-eat products. They are packed in flexible retort pouches which can be stored after sterilization at room temperature for 1 to 1.5 years.

2- I am attaching here the draft layout of my production facility for better understanding of segregation. all Bold black lines are illustrating masonry wall.

3- All products are cooked above 70 degree Celsius before filling and transferred to sterilizer within 1~2 hours.

I know there are some obvious issues with the layout (regarding material and workers flow) but I afraid it requires a heavy investment in wiping all out and re-construct a new premises without presenting a solid scientific justification to top management. Their main focus is on clear microbiological and other inspection reports.

Regards:
M.Zeeshan Zaki

Attached Files


Edited by Zeeshan, 01 February 2012 - 05:21 AM.


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Posted 03 February 2012 - 06:39 AM

Dear Zeeshan,

Thanks for yr input.

It appears to me that due to the characteristics of yr finished product, BRC6 categorises yr production facilities as low risk. Basically yr product appears to be analogous to canned foods, the latter are explicitly referred to as low risk. I am assuming that yr final retorting procedure is validated in a similar way.

It does appear to me that, assuming yr product pH corresponds to the situation for Low Acid canned foods, the same kinds of warning comment would also apply, such as to avoid abnormally high bacterial loads however BRC apparently assumes that such details are well under control.

I am somewhat uncomfortable with this (overall) result but that's the only BRC interpretation i can currently see. Maybe other people will have further insights.

BRC makes the comment that physical contamination is the most significant process hazard for such a system. Presumably they consider that chemical characteristics are "under control". Not sure I would agree with this confidence for canned goods, have seen several disasters due to defective lid sealing machines or can bodies (maybe classified within prerequisites). No experience with flexible pouches though.

Rgds / Charles.C


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Charles.C


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Posted 07 February 2012 - 05:13 AM

Dear Zeeshan,

Thanks for yr input.

It appears to me that due to the characteristics of yr finished product, BRC6 categorises yr production facilities as low risk. Basically yr product appears to be analogous to canned foods, the latter are explicitly referred to as low risk. I am assuming that yr final retorting procedure is validated in a similar way.

It does appear to me that, assuming yr product pH corresponds to the situation for Low Acid canned foods, the same kinds of warning comment would also apply, such as to avoid abnormally high bacterial loads however BRC apparently assumes that such details are well under control.

I am somewhat uncomfortable with this (overall) result but that's the only BRC interpretation i can currently see. Maybe other people will have further insights.

BRC makes the comment that physical contamination is the most significant process hazard for such a system. Presumably they consider that chemical characteristics are "under control". Not sure I would agree with this confidence for canned goods, have seen several disasters due to defective lid sealing machines or can bodies (maybe classified within prerequisites). No experience with flexible pouches though.

Rgds / Charles.C


That's classic!

I have just attended a one-day awareness course on BRC-issue-6 conducted by a BRC Lead Auditor. His analysis was also same for our product .

The only confusion that lasts is that the trainer and co-trainer were stating that although the new risk zone analysis is applicable for end product only, but it can also be applied to the constitutes of the end-product. Also, by reading the text of decision tree and other parts of the standard, it seems to me that sometime the the word "product" is also used for "raw or inprocess product or ingredients" and the word "area" sometimes is not intended to be used for whole premises/factory but a part of production area such as Filling and Sealing Area in my case.

BTW, out factory is going to be assessed on or before 20th of Feb. I request for good wishes for a successful audit. Due to extreme engagements I might not be able to be in touch with the forum till end of this Feb.

Thanks to all and best regards:
M.Zeeshan Zaki.


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Posted 14 June 2012 - 12:53 PM

Hello everyone. I have an issue on making a decision if production of eclairs considered high care or high risk. We don't use milk products in the custard, but we do cook it. Some eclairs we send fresh, but most of them are frozen.
I'm very confused, please help me to decide.
Thank you


Edited by mikysya, 14 June 2012 - 12:53 PM.


mikysya

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Posted 14 June 2012 - 12:58 PM

Hello everyone. I have an issue on making a decision if production of eclairs considered high care or high risk. We don't use milk products in the custard, but we do cook it. Some eclairs we send fresh, but most of them are frozen.

<br style="color: rgb(28, 40, 55); font-size: 13px; line-height: 19px; text-align: left; background-color: rgb(238, 242, 244); ">

I'm very confused, please help me to decide.

<br style="color: rgb(28, 40, 55); font-size: 13px; line-height: 19px; text-align: left; background-color: rgb(238, 242, 244); ">

Thank you



mikysya

    Grade - Active

  • IFSQN Associate
  • 15 posts
  • 2 thanks
0
Neutral

  • Ukraine
    Ukraine
  • Gender:Female
  • Location:Chicago, IL

Posted 14 June 2012 - 01:01 PM

Hello everyone. I have an issue on making a decision if production of eclairs considered high care or high risk. We don't use milk products in the custard, but we do cook it. Some eclairs we send fresh, but most of them are frozen.


Edited by mikysya, 14 June 2012 - 03:44 PM.




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