18 replies to this topic

[bnue]

We have to validate our kill step CCP which is set at 180 deg F. All of our products are baked cookies, bars, granola whic are free of all the allergens (no dairy, egg, nuts etc.) and have water activity less than 0.6.

While one way is to conduct a challenge study which we dont want to due to budget and time constraint, another way is to use studies already conducted by referencing existing research papers. Can anyone please help with such data?

[Charles.C]

We have to validate our kill step CCP which is set at 180 deg F. All of our products are baked cookies, bars, granola whic are free of all the allergens (no dairy, egg, nuts etc.) and have water activity less than 0.6.

While one way is to conduct a challenge study which we dont want to due to budget and time constraint, another way is to use studies already conducted by referencing existing research papers. Can anyone please help with such data?

Dear bnue,

Not familiar with yr product range but i can pose the basic requirements -

It depends what you mean (or perhaps a Standard) by "Validation" and "Kill" step (and in some opinions here - CCP).
Ideally haccp sets critical limits (eg temperature/time) based on a specific targetted microbial pathogen (or group of pathogens) and a certain level of achieved reduction.

Plus IMEX "cooking" validations for submission to official bodies typically require confirmation with actual data, eg test runs relating to times, temperature uniformity, probe locations , etc.

Plus any specific Regulatory issues ? Any specific Standard?

These threads here may be of interest -

http://www.ifsqn.com...dpost__p__45796

http://www.ifsqn.com...dpost__p__29020

http://www.ifsqn.com...dpost__p__41184

Rgds / Charles.C

[bnue]

Charles,

The thing is we are an allergen friendly snakc manufacturing facility and at one point of time it was decided that we would include baking temprature as a CCP. All of our baked products which are vegeterian and devoid of any allergens are baked to a minimum temperatureof 300 deg F for a minimum time of 10 minutes.

CCP was set at 180 deg F and is being checked (internal temperature of the baked products from top, middle, and bottom rack of every rack coming out of the oven) by the operator and verified by QA. But auditors who come in are asking for validation and since a challenge study at this time is out of question, they asked us to provide research papers supporting our theory that at 180 deg F, all major pathogens are killed - in this case Salmonella, e.coli, etc.

I have tried various universities and gone through many websites but found nothing specifically for baked products. Thank you so much for the links you provided. All those links were helpful and perhaps I can use them to tie to our theory.


Or perhaps I should change the CCP to CP? Any thoughts?

Thanks

Bnue

[imadoughguy]

Change it to a CP or Process Control SOP.

I think that is what the auditors are pointing you towards anyway.

If the product was not baked to internal temp 180 degrees (probably 300 in real time), what would happen? My guess is the product would be un-useable anyway, so it is not a CCP but actually an SOP.

We got rid of all the CCP's except Metal Detection in our bakery. Same product mix, cookie, muffins, donuts etc...

Phil

[Charles.C]

Dear bnue,

they asked us to provide research papers supporting our theory that at 180 deg F, all major pathogens are killed - in this case Salmonella, e.coli, etc.

Frankly, I think the auditor(s) are simply trying to see if you understand the microbiological basics of what you are talking about ?

Precisely which species are the 4 major pathogens referred ?

(Note that generic E.coli is not a pathogen. E.coli 0157... is ?)

Assuming yr reference reduction requirement is 6D, the relevant times for a temperature of 180degF should be not too difficult to locate from published tables.

For example the time for L.monocytogenes is 0.05 min (3secs) from the link I previously posted. E.coli O157 will probably be somewhat lower, most Salmonella species will probably be considerably lower (the times are directly proportional to respective species D values at the reference temperature).

I guess most people (even auditors) would accept 3secs as sort of instantaneous although validatory tests are usually required to be more detailed regarding temperature / time, etc characteristics.

But, if the 4th species (?) is a sporulating bacterium, it is quite possible that 180degF will not be sufficient.

Rgds / Charles.C

PS - i presume someone originally must have had some reason for choosing 180 degF ?

[bnue]

 HACCP research for Baking CCP_1.docx   20.2KB   784 downloadsThank you Charles and Phil.

I thought of getting rid of this CCP too but when I go though my HACCP to change the CCP to CP, I fail the "CCP determining flow chart questions" because I cant state there is no biological hazard from the raw ingredeints - flour, juices, dry fruits, etc. Perhaps thats why the group before me came up with the idea of adding a baking temperature CCP to control pathogens, although why 180 and not 170 I dont know.

Our suppliers do have their biological controls which is provided on their COA. Probably by stating Supplier control as well as internal control via GMP's I can change the CCP to CP? Phil, how do you account for the control of biological hazards from the raw ingredients?

From the links Charles provided and data from FDA website I have come up with some data to support my theory that at 180 deg f (actually I'm reducing it to 170 deg F) pathogens are killed.

Charles, I have uploaded my "supporting document" please can you go through it and provide your thoughts and suggestions? Would something like this suffice?

Thanks

bnue

Edited by bnue, 01 February 2013 - 06:13 PM.

[Charles.C]

Dear bnue,

I’m not sure who/what standard yr documents are being prepared for ?

My (EC) experience is with cooked foods / BRC for whom cooking “validation” basically required 3 things (ignoring aspects like calibration) –

(1) A statement/explanation of various microbial species which represented the pathogens of major concern plus a selection of the most heat resistant species within the group (which was L.mono).
(2) Explanation / calculation of necessary requirements to produce a minimum 6D reduction for species given in (1)(eg from tables of T vs t)
(3) A triplicate set of test runs/actual measurements demonstrating that requirements in (2) are achievable.

Notes

It is well-known that USA does not follow same logic as (1) in many cases, often preferring Salmonella.

I presume the actual temperatures (?) in yr product are >>> 170degF if oven set at 300degF. Assuming a batch operation, the validation would then seem to merely require proof that the product core temperature at (validated) coldest location in batch is consistently >> temperature setting from (2) which it presumably is.

The 6D factor may vary depending on specific situation however I would imagine that 6D conditions are easily attained in present case as per preceding paragraph.

You probably need to specify paragraph numbers for yr links. From a quick look, I couldn’t see any relevant content ?. Latest revision is 2009 from memory.

Yr summary may be a bit lacking with regard to (1-3) in my example above however it may be OK for yr specific purposes. ?

Rgds / Charles.C

PS - ADDED LATER Apologies that I omitted to mention that I could not open 2nd,3rd links in yr attachment until later (see my comments in post #14). Both links extremely valuable IMO although relatively old (original ca. 2001, page stated to be updated to 2012 though no later refs are obvious ). Nonetheless a later standard ref. (Microorganisms in Foods 6 , 2005) well supports the general conclusions in yr links, (eg see the 2nd, .png extract in post#10)

[bnue]

Dear Charles,

Thank you! Your feedback is invaluable. I'm doing this because this exists in our current HACCP flow chart. I'm doing my annual HACCP review and simultaneously preparing for our food safety audit where I'm sure the auditor will ask me how we came about with this temperature limit as the CCP.

- The actual internal temperatures have been consistently greater than 175 deg F for the past three years.(daily operators data available)

- The products are always baked at 330 deg F for 10-15 minutes.(below which the product wont meet our specifications and will be discarded)

My main concern is the providing the research document to proove that at 170 deg F pathogens are killed. I havent yet made a list of the pathogens of concern but am leaning towards Salmonella and (?).

I will follow your advice in formulating the validation report . I will keep you posted on how it goes. Thanks so much once again.

regards

bnue

[DAVE84]

we produce baked product in our facility. Very similar to yours. What i have done is conducted study of lethality, This was done by taking sample from different location of oven doors. Start from front of oven, you will have traveling time and oven band speed. by that you should be able to follow the product on the band and take sample. Take core temperature of sample at different points of oven from front to going to end of oven. Record temperature and time.


You should find spread sheet from american meat authority where you can insert time interval and temperature. That spreadsheet will count Fo value for you. I bet Fo for your product will be in 100. Taking that as a base change your CCP to just CP only. Have someone take product temperature after end of oven may be at frequency of once every two hour. That will help you to say that oven is functioning correctly and if it works correcly it will kill bacteria. Usualy in bakery lethality is many times more than required so no mone keeps oven as CCP. Still i have seen few doing that but i would say it will be waste of time.


I have gone through very strickt audits and no one has disagreed with my work. I had one auditor challange it once but i was able to explain and he was find.





Hope this helps

[Charles.C]

Dear Dave,

I agree with you that calculating the F value of the overall process is a more rigorous solution and might satisfactorily overwhelm unfamiliar auditors. I also use such a procedure for validation since involved with product cooking times of a few minutes only.

I normally work more with D-value calculations although these are of course directly related to F values, eg.

F-value is a numeric way to express the amount of heat received by bacteria at a reference temperature. Stated differently, F-value is the equivalent time spent at a given temperature in terms of microbial kill. F-values allow the direct comparison of two or more processes. For example, testing may show that the same F-value (e.g., F185 = 10 min) is accomplished by heating containers of product for either 1 h at 195ºF or for 2 h at 185ºF: both providing the same effective kill that would be achieved by instantly heating the product to 185ºF, holding for 10 min, then instantly cooling the product. F-values include the lethal heat the product receives during the heating and cooling portion of the process.
F-values and D-values are related in that a process F-value usually represents multiple D-values. If a research study determined that an organism’s D-value was 1 min at 185ºF (D185 = 1 min), then a process with a F185 = 10 min would achieve 10 decimal reductions for the target microorganism, or a 99.99999999 % kill (Rippen, 1998).

http://seafood.ucdav...t03.htm#F-value

(Excel sheets for direct F value estimation are linked (maybe even attached) in some other threads on this forum. I guess that the appropriate z-value for the currently discussed baked products is probably rather different to meat matrices though (??)).

I had understood that for process in OP, the slowest location of heated product still (validatably) exhibits a “plateau” temperature / time period at values far in excess of those required to match 6D settings. If so, I would hv thought a simpler control procedure / critical limits could possibly be adequate for validation also, monitored by direct probes in the baking product (direct use of oven temperature / time IMEX is usually restricted to routine CCP monitoring / correlation to probe data). On the other hand, perhaps the typical target in baked products is higher than 6D or the process T vs t shape is different to above (??)).

I think that yr comments regarding categorisation as CCP / CP are a somewhat different issue for audit purposes. I got the impression from other threads that product will typically be auto-rejected due appearance if inadequate temperature/time hence no risk that such product will reach the final consumer. Or perhaps it depends on eyesight. Seemed to be a 50/50 type split on CCP / "CP".

Rgds / Charles.C

PS - i imagine the time/temperature profile for baking step is similar to this (stated) typical example for bread -

 baking profile.png   50.97KB   72 downloads

Another general microbiological comment -

 micro. hazards baked products.png   57.24KB   55 downloads

(Presumably the usual [vegetative] suspects may occur in the ingredients, eg Salmonella, L.mono, S.aureus, a common spore source is Bacillus cereus )

[imadoughguy]

My question is where are you introducing a biological hazard to your food? If the ingredients come in clean (supplier guarentee, COA's etc...) then your GMP's should keep them free from biological issues so why do you think you need to CCP a "kill" step?

Yes baking/frying anything to 200 degrees internal temp will kill pathogens that are in the product at the time of baking/frying. If based on time and temp say 350 degrees for 35 minutes is what it takes to get your muffin internal temp to 200 degrees, if it were not baked at 350 degrees for 35 minutes you would not have a useable muffin right? So your control step is 35 minutes at 350 degrees to fully bake the muffin.... the fact that it gets 200 degrees internal temp is just a part of making a sellable muffin.

Bottom line is internal temp is not a CCP if your ingredients are clean and your GMP's are not adding pathogens to your food. If either of these is not true you need to address that with PRP's.

Phil

[Charles.C]

Dear imadoughguy,

Food safety would certainly be more readily maintained if bacteria were invariably as well-behaved as per your post.

however, as long as you can validate your assumptions for your situation, the HACCP significance (or lack of) for baking is presumably confirmed.

[Some texts suggest that the term "ubiquitous" is well-deserved for some microbial species. And also that 100degC can be inadequate to eliminate some spores since the times involved (eg for 6D) are incompatible with maintaining saleable quality].

IMO, the argument over whether a baking CCP exists or not is ultimately just a matter of opinion / interpretation.

Rgds / Charles.C

[DAVE84]

Hello Charles,

Yes you are right on z value but i would dig more if my F0 value comes to near 6D or perhaps 12D. But if with z=18 i get about 100 log reduction than it would not make big difference if z will be 15 or so.


you are also right if oven fails you will come to know right away since your product will not be cooked and in bakey workd you will notice it right away from color of product. But in food safety world we always try to avoid terms like we will know by product color etc so i prefer goting by scientific numbers and one of it is temperature of core or second measure can be measuring color of product.



Dave

[Charles.C]

Dear Dave,

Yes, I initially had much the same thoughts as your z-value comments.
However I was rather taken aback (see below) after looking at thermal data from a few seemingly validated publications. Unfortunately I was unable to find much data on current products of interest.
I have no wish to be alarmist since B.cereus (the selected pathogen of concern) only produces toxin at elevated bacterial levels and the products in OP all presumably have adequately "low" aw levels (<0.8 acc. to bnue, [location unspecified]) and were derived from good quality ingredients.
(Epidemiologically the types of product mentioned in the OP certainly seem to have an excellent safety track record over many years)

I haven’t seen many detailed posts here on “spore” aspects so I thought a little background detail might be of interest -

B.cereus seemed (from literature sources) the most appropriate sporing target to compare data against due the type of foods under discussion.
After a little digging, I was surprised to meet this comment in a rather authoritative looking document (attachment pp1 below) –

Only heat treatments used for canning of low acid foods will ensure a complete destruction of spores of B. cereus.

Followed by –

Inactivation of spores of B. cereus can only be guaranteed by a heat process equivalent to that used for low acid canned foods (F0 =3). However, this control measure cannot be used in most foods without dramatically altering their quality.

Inhibition of growth of B. cereus can be achieved by reducing water activity, pH and/or temperature. Temperature below 10°C greatly slows multiplication and temperatures below 4°C prevent it. Rapid cooling of heat treated foods through the temperature range supporting growth will also minimise multiplication before storage. After cooking, cool through the temperature range 55°C to 10°C as quickly as possible; store below 10°C (ideally below 4°C). Rapid cooling can only be achieved if the portion size is relatively small.

B. cereus, mainly spores, can persist on the surface of some processing equipment, which may increase the contamination of processed food. Good hygienic practices, HACCP, GMP, and using equipment designed to allow efficient cleaning, could reduce the initial number of B. cereus in processed foods.

Other pathogenic Bacillus spp. have some features similar to B. cereus: they produce heat resistant spores and they must be present in high numbers in foods to cause diseases. Control measures presented above for B. cereus certainly contribute to control other pathogenic Bacillus spp. However, there is little information in the literature on other pathogenic Bacillus spp. No routine methods easily detect and enumerate other species of Bacillus that could be involved in foodborne poisoning and no methods distinguish pathogenic strains among these species. The temperature and pH ranges allowing growth of pathogenic Bacillus other than B. cereus are not known. Therefore control measure specific to other pathogenic Bacillus spp are not available.

The same document also has a fascinating compilation of D values (ie time to achieve decimal reduction, referenced to mostly 90-100degC) for a range of foods (Table5, see pg 23). The most obvious feature is the wide variation in values, eg 0.3 to 100 min. Basically a 6D requirement involves multiplying the (maximum?) quoted D values by 6 to get a minimum time in minutes for a perfect (ideal) rectangular T vs t profile.

Another paper (pp2) for rice, which does indeed have a well-known history for occasional problems due B.cereus, quoted D(95degC) values of 1.5 to 36.2 min.

A third, 2000, paper (pp3) looks at necessary controls for a range of familiar spore-formers and more or less agrees with B.cereus comments in previous documents.

 pp1 - Bacillus cereus in foodstuffs, 2005.pdf   199.18KB   312 downloads
 pp2 - B.cereus, inactivation in rice 2007.pdf   265.93KB   205 downloads
 pp3 - control of bacterial spores, 2000.pdf   742.91KB   275 downloads

Rgds / Charles.C

PS (added later) @bnue, I forgot to note earlier that i was unable to open the last 2/3 FDA links you previously provided. Seem to be working today and i found them excellent in readability and scope (although the comment in one article that biscuits have a high aw seems rather odd). Pls note my added comments in post # 7. I repeat the 2 links here for convenience to other posters -

http://www.fda.gov/f...s/ucm094145.htm

http://www.fda.gov/F...s/ucm094147.htm

2 sections which seemed directly useful are -

3.4. Processing steps

The current definition of "potentially hazardous foods" considers the effect of processing in much the same way that it considers pH and aw: it divides foods into two categories. Low-acid canned foods in a hermetically-sealed container do not require temperature control for safety. This rigid definition fails to address less processed foods, in less robust packaging, which still would not require temperature control for safety. Consider a baked product, such as a pie, with a pH of 5.5 and aw of 0.96. Since this product is baked to an internal temperature >180 °F (82 °C) to set the product structure of the pie, it will not contain any viable vegetative pathogens. Any pathogenic spores that survive the baking process will be inhibited by the pH and aw values listed above (ICMSF 1996; see tables 2 and 5). If the product is cooled and packaged under conditions that do not allow recontamination with vegetative pathogens, the product is safe and stable at room temperature until consumed, or until quality considerations (that is, staling) make it unpalatable.

Scientifically sound criteria for determining whether foods require time/temperature control for safety should consider 1) processes that destroy vegetative cells but not spores (when product formulation is capable of inhibiting spore germination); 2) post-process handling and packaging conditions that prevent reintroduction of vegetative pathogens onto or into the product before packaging; and 3) the use of packaging materials that while they do not provide a hermetic seal, do prevent reintroduction of vegetative pathogens into the product.

(appreciate that baked "pie" not relevant this thread, was temperature note that attracted me )

and -

5.4. Time/temperature control

Although baked and fried cereal-grain products (for example, cakes, breads, muffins, and biscuits) have a high aw, a number of reasons may justify their shelf-stability: they have a long history of safe storage at ambient temperature; processing temperatures and moisture reduction, especially on the surface, preclude the growth of pathogens; and they are often formulated to include ingredients that enhance product safety and stability so as to permit distribution without temperature control for limited periods of time. Ingredients that are used to enhance safety and stability include humectants to reduce aw (sugars and glycerine), preservatives (calcium propionate, potassium sorbate, sorbic acid), acids to reduce pH (vinegar, citric acid, phosphoric acid, malic acid, fumaric acid), spices with antimicrobial properties (cinnamon, nutmeg, garlic), and water-binding agents to control free water (gums, starches). The primary mode of spoilage of baked goods is mold growth, which is visible and alerts the consumer to avoid consumption, further reducing the risk of illness due to spoiled product. These characteristics plus their long history of safe storage at room temperature would allow these products to be stored at ambient temperature. Boiled or steamed cereal products, such as rice, require time/temperature control after preparation due to the increase in aw.

The articles are laudably frank in commenting that the precise reasons for good safety records are not always immediately evident.

i deduce that above extracts may have provided the stimulus for the original nomination of 180degF however this becomes problematic if not matched to yr routine data as you suggested earlier.

I enclose 2010 extract indicating that (with exception of 2-3 species not AFAIK relevant in present case) L.mono is the "winner" for thermal resistance amongst common (vegetative) pathogens at approx. 60degC although this does not automatically ensure a similar listing at temperatures around 175degF (ca.80degC). If you can find such data, it will demonstrate that pathogens of concern in vegetative states can be considered as (6D) "eliminated" assuming that the z value in my previous posted table for L.mono is still valid or not changed to a more "resistant" value.
The spore related aspects are, IMO, adequately (validatably) explained by the comments in yr FDA links as quoted above.
 D values for various microbial pathogens approx 60degC.png   276.59KB   23 downloads
(extracted from -  pp4 - food safety in hospitality sector.pdf   2.27MB   258 downloads

[sadean]

I am not sure of all of your incoming ingredients but I would assume eggs and flour are both present, therefore you do have pathogens as a hazard. You need to determine which ones are of concern. I have listed some that may apply, but this isn't necessarily accurate for you. I have also included a bit of a validation that you could adopt for your products. In my opinion, your cook temperature is to high to be the critical limit. Keep in mind that you are cooking it at that temperature for quality reasons and not necessarily to kill pathogens. You are obviously killing pathogens as you are cooking to 82C and only need to around 71-72C. If you took a lot of temperatures in various locations, indicating that the internal temperature has exceeded the kill temp required, then you may be able to eliminate the CCP altogether. You need to do a test to determine cold spots in your oven, then you need to show that this is the location you take your internal temperature at. Also remember that cook temperature is different than the internal temperature of your product and the internal temperature is really what you need to know. I don't think that you want to be taking internal temperatures on an on-going basis, and for this reason, you may want to eliminate the CCP altogether. Many bakeries do not have cooking as a CCP. Cooking in meat is very different as there really is a risk of contamination here, but you don't hear about E.coli outbreaks in shortbread too often. Hopefully the information I provided will help you to put together your own validation. Good luck!

1) Salmonella spp.: The temperature necessary to kill Salmonella spp. is 71.1^oC. Salmonella is a non-spore-former.

2) E.coli 0157:H7: The temperature necessary to kill E.coli 0157:H7. is 71.1^oC. E.coli 0157:H7 arenon-spore-formers.

3) Listeria monocytogenes: The temperature necessary to kill Listeria monocytogenes is 71^oC. Listeriamonocytogenes is a non-spore-former.

4) Clostridium botulinum: The vegetative cells of clostridium botulinumcan be killed at pasteurization temperatures (71^oC). Toxins are produced at a pH 4.83 – 5.2.

The temperature that you are cooking to is not going to kill toxins, however the water activity of your finished product will not allow the growth of toxins

You then need to list your references you used to come up with the scientific data (Microorganisms in Food 6, Microbioal Ecology of Food Commodities)


Aliterature review indicates that pathogens cannot grow in products with a wateractivity of <0.83. Table A also contains the minimum water activity growth limitassociated with the pathogens that may be associated with the "name product". The resulting product has an a_w of<"list water activity" which is well below the minimum growth limit of 0.83 for water activity;therefore these pathogens will not survive in the finished product.

Table A:Pathogens associated with "name finished product" and the minimum water activity growth limitand temperature to destroy the pathogens.

Pathogen Water Activity Temperature (^oC) Salmonella spp. 0.93 72 Escherichia coli 0.95 71 Staphylococcus aureus 0.83 71Listeria monocytogenes0.9271

[sadean]

Ignore the information on pH as this isn't relevant to your products. It would be more for a sauce or product in which you were using pH as a CCP. Sorry-I forgot to remove it!

[Charles.C]

Dear sadean,

Many thks yr (various) inputs. Its an interesting topic. Have a few comments on yr post.

The OP mentioned no eggs were present. Flour for sure.

You are obviously killing pathogens as you are cooking to 82C and only need to around 71-72C.

Vegetative yes, spore formers quite likely no. As my previous post.

1) Salmonella spp.: The temperature necessary to kill Salmonella spp. is 71.1oC. Salmonella is a non-spore-former.

2) E.coli 0157:H7: The temperature necessary to kill E.coli 0157:H7. is 71.1oC. E.coli 0157:H7 are non-spore-formers.

3) Listeria monocytogenes: The temperature necessary to kill Listeria monocytogenes is 71oC. Listeriamonocytogenes is a non-spore-former.

I presume the word “kill” refers to a 6D reduction in each case. Or ??

IMO it is also important to include an idea of the minimum time for 6D thermal destruction data, eg for z = 7.5 degC, 71degC would imply for L.mono a minimum time of 1.5 minutes so actual thermal profile might be important in some cases. (a common UK requirement is minimum 2mins / 70degC core temperature or equivalent for a variety of products).
From memory, attainment of 75degC is sometimes quoted as a “generic” instantaneously effective value for "pathogens" . In truth it simply “depends” IMO.

Just for info, here are some quite interesting relative D values at 70degC for chilled foods (note the considerable change in some absolute and relative values compared to my earlier posted attachment for 60degC ) –

•

Listeria monocytogenes is the most heat-resistant vegetative pathogen of significance in chilled foods, and as a consequence, all other vegetative pathogens, such as Staphylococcus aureus, Campylobacter, E. coli and Salmonella, will also be heat-inactivated (i.e. at least a Log 6 reduction).
• Typical D values for infectious pathogens at 70°C are:
• L. monocytogenes 0.3
• C. jejuni 0.0001
• E. coli (including O157:H7) 0.001
• salmonellae 0.01
• S. aureus 0.1
• V. parahaemolyticus 0.001
• Y. enterocolitica 0.01

In contrast to the vegetative species above –

Typical D value for psychrotrophic C. botulinum at 90°C is 1.5. Most bacterial spores, including spores from mesophilic C. botulinum and cold growing B. cereus are much more heat resistant than those from cold growing C. botulinum and will not be inactivated by the pasteurisation treatments presented in this table {data was given for the range of temperatures 80-100degC)

( ECFF 2006)

The resulting product has an aw of<"list water activity" which is well below the minimum growth limit of 0.83 for water activity;therefore these pathogens will not survive in the finished product.

Inability to grow does not necessarily equal non-survival, eg
http://www.campdenbr...a-dry-foods.php

Nonetheless, I do agree with you that a good argument for a non-CCP can be presented. Some people just opt for a peaceful (auditorial) life and stay traditional.

Rgds / Charles.C

[imadoughguy]

Charles,

You are correct on all counts. As in most things, Food Safety Programs are situation specific.

HACCP requires us to determine likely siginificant hazards, and to find a way to reduce the risk to an acceptable level. Each manufacturer must determine for themselves what risk are likely, and what an acceptable level of reduction is, and if that requires a CCP or not.

Most auditors will raise questions if they think you are under estimating either one.

Thanks for your rejoinder, sometimes I need to be reminded that what I would do is not always what everyone else should do. :-)

Have a great weekend everyone,
Phil

[sharma]

I am not sure of all of your incoming ingredients but I would assume eggs and flour are both present, therefore you do have pathogens as a hazard. You need to determine which ones are of concern. I have listed some that may apply, but this isn't necessarily accurate for you. I have also included a bit of a validation that you could adopt for your products. In my opinion, your cook temperature is to high to be the critical limit. Keep in mind that you are cooking it at that temperature for quality reasons and not necessarily to kill pathogens. You are obviously killing pathogens as you are cooking to 82C and only need to around 71-72C. If you took a lot of temperatures in various locations, indicating that the internal temperature has exceeded the kill temp required, then you may be able to eliminate the CCP altogether. You need to do a test to determine cold spots in your oven, then you need to show that this is the location you take your internal temperature at. Also remember that cook temperature is different than the internal temperature of your product and the internal temperature is really what you need to know. I don't think that you want to be taking internal temperatures on an on-going basis, and for this reason, you may want to eliminate the CCP altogether. Many bakeries do not have cooking as a CCP. Cooking in meat is very different as there really is a risk of contamination here, but you don't hear about E.coli outbreaks in shortbread too often. Hopefully the information I provided will help you to put together your own validation. Good luck!

1) Salmonella spp.: The temperature necessary to kill Salmonella spp. is 71.1^oC. Salmonella is a non-spore-former.

2) E.coli 0157:H7: The temperature necessary to kill E.coli 0157:H7. is 71.1^oC. E.coli 0157:H7 arenon-spore-formers.

3) Listeria monocytogenes: The temperature necessary to kill Listeria monocytogenes is 71^oC. Listeriamonocytogenes is a non-spore-former.

4) Clostridium botulinum: The vegetative cells of clostridium botulinumcan be killed at pasteurization temperatures (71^oC). Toxins are produced at a pH 4.83 – 5.2.

The temperature that you are cooking to is not going to kill toxins, however the water activity of your finished product will not allow the growth of toxins

You then need to list your references you used to come up with the scientific data (Microorganisms in Food 6, Microbioal Ecology of Food Commodities)


Aliterature review indicates that pathogens cannot grow in products with a wateractivity of <0.83. Table A also contains the minimum water activity growth limitassociated with the pathogens that may be associated with the "name product". The resulting product has an a_w of<"list water activity" which is well below the minimum growth limit of 0.83 for water activity;therefore these pathogens will not survive in the finished product.

Table A:Pathogens associated with "name finished product" and the minimum water activity growth limitand temperature to destroy the pathogens.

Pathogen Water Activity Temperature (^oC) Salmonella spp. 0.93 72 Escherichia coli 0.95 71 Staphylococcus aureus 0.83 71Listeria monocytogenes0.9271
 

Hi by chance can you share the source for this information.( Kill temperatures ) I am documenting this for our Program. Auditor asked us to check the temperature of oven at every run - To verify that if the oven display says 350 it is actually 350. We get our oven calibrated every year. Temperatures of ovens are pre set and all the baking is done 350F - 370F ( few products baked at 330F ). We did oven temperature monitoring for few months. Collected data shows that all the temperatures recorded are + 10F , but the wire that goes inside the industrial ovens get broken so on recommendations of our internal auditor we stopped doing it as we had enough data. But I still want to have some more articles or documents to support our study.