13 replies to this topic

[jwatford]

Dear Colleagues,

 

Looking for feedback concerning a HACCP Plan.

I am new to a company making cakes and cheesecakes and as I am reassessing the HACCP plan I am not convinced that baking temperature needs to be a CCP. There is minimal risk with raw materials for micro and all products are cooled, placed in a blast freezer, shipped and delivered to a customer frozen.  The end user only thaws product for consumption shortly and then it is to be refrgierated or frozen. My conclusion is that the freezing is more critical than the baking to elimate any micro hazards. 

Thoughts? Comments?  Feedback will be helpful.

[Charles.C]

Dear Colleagues,

 

Looking for feedback concerning a HACCP Plan.

I am new to a company making cakes and cheesecakes and as I am reassessing the HACCP plan I am not convinced that baking temperature needs to be a CCP. There is minimal risk with raw materials for micro and all products are cooled, placed in a blast freezer, shipped and delivered to a customer frozen.  The end user only thaws product for consumption shortly and then it is to be refrgierated or frozen. My conclusion is that the freezing is more critical than the baking to elimate any micro hazards. 

Thoughts? Comments?  Feedback will be helpful.

 

Dear jwatford,

 

Assuming by freezing you mean achieving a core temperature approx 0degF, this does not eliminate microbial pathogens. Not normally regarded as a CCP for this hazard IMO.

 

Regarding baking step, as in some haccp texts, the opinions on this forum are divided, I guess, something like 50/50 as to whether baking is a CCP or not for reasons such as insufficient temperature will be visibly obvious in an unusable product, ie no operational hazard. The choice may depend on how much you enjoy arguing with auditors.

 

Rgds / Charles.C

[jwatford]

Thanks Charles C.  We have completed some freezing studies to demonstrate that the product is cooled to ambient within 1 hour, placed in the blast freezer at -15 and is at 0 within 2 hours.  The major ingredients for  most products are egg, cream cheese and sour cream and the baking step, temp and time is more for quality than food safety.

[dunkleyt]

Dear jwatford,

 

I may offer some food for thought, here are some questions I would probably start with if I was your customer:

• Are any ingredients raw? What specific assurances are available in regards to the recipe ingredients (CofA's for every lot? Letters of guarantees from suppliers on file?)?
• If internal product temperature is not a CCP then by what margin does the quality standard exceed the critical limit required to achieve food safety? Will the QCP be treated with the same rigour as though it was a CCP)? (Agree with previous post that we cannot rely as freezing as a kill step - and would expect the manufacturer to fuly validate why a kill step is not required)
• How will the customer be assured the finished product is pathogen free (as it requires no further cooking), and will not further support the growth of microorganisms during the intended shelf-life once thawed?

Also, if product is to be served in a retail environment then all sorts of interesting practices should be reasonably anticipated and it is important to prepare for the worst case scenario. So, even if this customer says they will be using the product quickly once thawed - what does this really mean? (How will it be thawed? Will it be served immediately once thawed? 4 hours after thaw? 12?) FDA food code allows TCS foods to be stored up to a maximum of 7 days at refrigerated temperatures if properly labelled. Alternately time control may be used if stored ambient for very short periods.

 

Have these potential scenarios been addressed in the product assessment and what end-use instructions will be included on the label for safety or optimal quality?

 

Regards,

 

 

 

 

 

[cazyncymru]

Excuse my ignorance here, but I would have said that, via my micro risk assessment template , eggs and cream cheese would be high risk (Salmonella / Listeria) and sour cream is a cultured product, and therefore the cook step would a CCP

 

 

Caz x

[Charles.C]

Hi Caz,

 

The argument(s) tends to revolve around the interpretation of baking as a control measure for the hazards you mention.

 

Hazard significance for a RTE product is AFAIK typically evaluated with respect to the consumer risk at the point of consumption.

I think the (“con-CCP”) haccp conceptual logic (here) is that  any failure to control the baking temperature/time  of such magnitude to not eliminate vegetative pathogens would automatically also yield a product of visibly useless quality. So the product would never reach the consumer and  there is no significant hazard. This proposition would require validation of course.

Spore formers seem to be rather ignored in most haccp discussions of this process but may not always be  insignificant IMO. They are considered in my attachment below.

 

Presumably if above logic is believed inadequate, your comments will be (CCP) - meaningful.

 

I have attached  an extract from one analysis which agrees with yr suggestion however some people  here will surely disagree with (at least) one of the decision tree responses.

 

 cheesecake, baking step, pro-CCP.png   158.75KB   99 downloads

 

There are a few discussions on this topic elsewhere here, my earlier 50/50 was a guesstimate. For example -

 

http://www.ifsqn.com...ccp/#entry41184

 

Rgds / Charles.C

[jwatford]

Thanks for the feedback, I suspected that it would not be justified as a kill step.  Also I was not included freezing as a kill step just an added meaure to minimize micro growth.  All products are frozen. Minimal micro sensitive ingredients.

The baking of many products (breads, biscuits, etc) is not considered to be a CCP as you are baking to attain a quality of product and not a "kill step" in the process.

 

Have written many food safety plans and never challenged  in an audit.

 

If the product does not reach the determined temperature, the product will not bake to the quality requirements. e.g. bread will not rise, therefore cannot be sold as a product. A quality issue not safety.

 

Stam

Safefood360

[jwatford]

Thanks dunkleyt.  We have completed a risk assessment for ingredients and we have coas for every lot, letter of guarantee and food safety audits on file for each ingredient.  The cooking QCP is treated with the same rigor as a CCP, right now the cooking step is a CCP but upon my review and revision I was questioning this.  The QCP internal temperature is 140. The product is intended to be frozen, refrigerated, thawed and refrigerated/frozen again and that is more for quality attributes. We have included storage and thawing instructions on labels.  Thanks for the questions, it is a great forum as there are not always this many techincal experts under one roof.

Dear jwatford,

 

I may offer some food for thought, here are some questions I would probably start with if I was your customer:

• Are any ingredients raw? What specific assurances are available in regards to the recipe ingredients (CofA's for every lot? Letters of guarantees from suppliers on file?)?
• If internal product temperature is not a CCP then by what margin does the quality standard exceed the critical limit required to achieve food safety? Will the QCP be treated with the same rigour as though it was a CCP)? (Agree with previous post that we cannot rely as freezing as a kill step - and would expect the manufacturer to fuly validate why a kill step is not required)
• How will the customer be assured the finished product is pathogen free (as it requires no further cooking), and will not further support the growth of microorganisms during the intended shelf-life once thawed?

Also, if product is to be served in a retail environment then all sorts of interesting practices should be reasonably anticipated and it is important to prepare for the worst case scenario. So, even if this customer says they will be using the product quickly once thawed - what does this really mean? (How will it be thawed? Will it be served immediately once thawed? 4 hours after thaw? 12?) FDA food code allows TCS foods to be stored up to a maximum of 7 days at refrigerated temperatures if properly labelled. Alternately time control may be used if stored ambient for very short periods.

 

Have these potential scenarios been addressed in the product assessment and what end-use instructions will be included on the label for safety or optimal quality?

 

Regards,

[jwatford]

Hi Caz,

 

The argument(s) tends to revolve around the interpretation of baking as a control measure for the hazards you mention.

 

Hazard significance for a RTE product is AFAIK typically evaluated with respect to the consumer risk at the point of consumption.

I think the (“con-CCP”) haccp conceptual logic (here) is that  any failure to control the baking temperature/time  of such magnitude to not eliminate vegetative pathogens would automatically also yield a product of visibly useless quality. So the product would never reach the consumer and  there is no significant hazard. This proposition would require validation of course.

Spore formers seem to be rather ignored in most haccp discussions of this process but may not always be  insignificant IMO. They are considered in my attachment below.

 

Presumably if above logic is believed inadequate, your comments will be (CCP) - meaningful.

 

I have attached  an extract from one analysis which agrees with yr suggestion however some people  here will surely disagree with (at least) one of the decision tree responses.

 

cheesecake, baking step, pro-CCP.png

 

There are a few discussions on this topic elsewhere here, my earlier 50/50 was a guesstimate. For example -

 

http://www.ifsqn.com...ccp/#entry41184

 

Rgds / Charles.C

Thanks Caz for the feedback.  The cream cheese and eggs are pasteurized, stored refrigerated, baked, stored frozen.  There is not much opportunity for the product or raw amterial to be at ambient temepratures for the organism to grow.

[Charles.C]

Dear jwatford,

 

The QCP internal temperature is 140.

 

 

140 what ?

 

Rgds / Charles.C

[jwatford]

Dear jwatford,

 

 

140 what ?

 

Rgds / Charles.C

Sorry Charles the internal baking temperature that is set up now for the CCP is 140 Degrees Fahrenheit. This standard was set up long before I was here and I am questioning it as a CCP.

[Charles.C]

Sorry Charles the internal baking temperature that is set up now for the CCP is 140 Degrees Fahrenheit. This standard was set up long before I was here and I am questioning it as a CCP.

 

Dear jwatford,

 

Thks for the clarification.

 

A product core temperature of 140degF is about 60degC

 

Baking not my process area so I am treading slightly cautiously.

 

From a purely baking POV, 140degF seems quite low in comparison to most of the core temperature values I’ve seen mentioned in other threads here. A temperature below this may well not readily achieve the typical requirements for pathogen elimination (eg 6D reduction) unless the process time is very long.This micro. characteristic would support classification as a CCP unless accompanied by a simultaneous, quality auto-rejection event.

 

For comparison, the haccp plan I extracted from earlier has a  baking step of 140degC / 55min so as to achieve a critical core temperature of (minimum) 72degC (approx 162degF). (my chart for a 6D destruction of L.mono. starts at core temperature of 63degC for 17min. [However  if yr haccp anaysis is based on Salmonella as a target pathogen the corresponding time will be shortened]).

 

It would be interesting to know how a core temperature of 60degC  was validated as yr critical limit if baking is set as a CCP and for what time of baking.

 

Rgds / Charles.C

 

 

PS - (Added later)

 

As far as (haccp) raw material risk is concerned, although it's subjective, you may have to consider the concept that some  ingredients are automatically considered (from general experience) to be a potential source of certain pathogens, eg Salmonella, L.mono,.This is regardless  of COAs etc.

 

Similarly to Dunkleyt’s comments, it seems to me you need more info. on yr process regarding (a) yr current capability for  target pathogen reduction, (b)  the specific ability to quality-reject product which has failed to reach a core temp. of 140degF ,(c) the relative micro. implications of (b).

 

I suspect the “conservative” option of nominating baking a CCP is likely to be the less argumentative route as far as auditors are concerned but you need to validate yr critical limits.

 

I also suggest you have a look at this thread which addresses some related micro. problems  –

 

http://www.ifsqn.com...ion/#entry58612

Edited by Charles.C, 07 September 2013 - 01:28 PM.
added PS

[cazyncymru]

I get a CoA for all of my incoming raw materials. I still test everything. And I find issues.

 

I actually questioned 1 supplier on how they tested and I was shocked by their answer, and they believe, because they are UKAS accredited they are doing it right (an internal on site lab)...... I now insist on their raw materials being positively released before we use them!

 

Caz