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HACCP- Product must be cooked before consuming


Best Answer Pizza&Sandwich, 22 October 2013 - 05:14 PM

Just because your label says it must be cooked, doesn't remove you from any liabilities.

 

Take a look at prepared cookie dough. It says must be cooked/baked, do not eat raw cookie dough. Yet people have, and have sued and won.

 

The definition of a CCP is a step or process that prevents, eliminates, or reduces a hazard to an acceptable level. What are your potential hazards? Associated risks? Then ask: Does this process prevent, eliminate, or reduce the hazard(s) to an acceptable level? If yes, then I would say it's still a CCP.

 

We make pizzas and are USDA inspected. Our CCP is time & temperature control of the ingredients in process, even though the cooking step stated on the labels is essentially a kill step.

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#1 CaliforniaFS

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Posted 22 October 2013 - 04:48 PM

Your thoughts please?

 

Working with asparagus, all of our packaging states product must cooked before consuming.

 

Does this mean that it can over rule the CCP in a HACCP plan? 

 

I have the Chlorine level in the washing process as a CCP because it disinfects the product and the chlorine level must be maintained to accomplish this., 

 

Since the product has to be cooked before eating does this mean I can still monitor hte chlorine level but don't need to call it out as a CCP?

 

I used to work with Citrus, and we did have to have this process as a CCP because of cooks using the zest of an orange or a lemon. 

 

 

 

 


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#2 Pizza&Sandwich

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Posted 22 October 2013 - 05:14 PM   Best Answer

Just because your label says it must be cooked, doesn't remove you from any liabilities.

 

Take a look at prepared cookie dough. It says must be cooked/baked, do not eat raw cookie dough. Yet people have, and have sued and won.

 

The definition of a CCP is a step or process that prevents, eliminates, or reduces a hazard to an acceptable level. What are your potential hazards? Associated risks? Then ask: Does this process prevent, eliminate, or reduce the hazard(s) to an acceptable level? If yes, then I would say it's still a CCP.

 

We make pizzas and are USDA inspected. Our CCP is time & temperature control of the ingredients in process, even though the cooking step stated on the labels is essentially a kill step.


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#3 darwich

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Posted 22 October 2013 - 09:38 PM

great topics


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#4 QSDA

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Posted 22 October 2013 - 10:16 PM

Think you have missed the final question in the decision tree

 

Will subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level?


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#5 Charles.C

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Posted 23 October 2013 - 12:06 AM

Think you have missed the final question in the decision tree

 

Will subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level?

 

Indeed. However the "invisible" consumer step may also be open to debate perhaps.?

 

AFAIK, the particular use of chlorine in the wash water in vegetable processing is to prevent wide-scale cross contamination of the produce in addition to reducing the level of potential pathogenic species present.

 

In the event of loss of control, it is not impossible that the consumer 's cooking procedure is insufficient to cope with such a situation.?

 

Rgds / Charles.C


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#6 Tony-C

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Posted 23 October 2013 - 04:39 AM

In the event of loss of control, it is not impossible that the consumer 's cooking procedure is insufficient to cope with such a situation.?

 

Rgds / Charles.C

 

That would be my concern as well. I don't like to overcook my Asparagus and agree with your point that Chlorine is quite likely a CCP in this process.

 

Regards,

 

Tony


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#7 QSDA

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Posted 23 October 2013 - 08:48 AM

That would be my concern as well. I don't like to overcook my Asparagus and agree with your point that Chlorine is quite likely a CCP in this process.

 

Regards,

 

Tony

Hi all

I think that the decision is the processors' as usual.

Should consider use of product and possible misuse in step 2 on the HACCP plan, but control of the end user is outside the company control (even flash blanching would raise the surface temperature to adequate levels).

By this logic the sale of raw meat would be impossible as it could be eaten without further cooking.


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#8 Charles.C

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Posted 23 October 2013 - 09:23 AM

Dear QSDA,

 

I think that the decision is the processors' as usual.

Well, hopefully, a risk-based one.

control of the end user is outside the company control

 

Since there will presumably be no warning labelling, that is the problem.

even flash blanching would raise the surface temperature to adequate levels

Would you like to validate this "flash blanching" for vegetables? Say, 10^5 E.coli O157 / gm, core temperature 30degC, 5second "flash"

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#9 Tony-C

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Posted 23 October 2013 - 03:09 PM

Should consider use of product and possible misuse in step 2 on the HACCP plan, but control of the end user is outside the company control

 

Not sure what step 2 of a HACCP plan is but under CODEX Guidelines 'The application of HACCP principles consists of the following tasks as identified in the Logic Sequence for Application of HACCP............ 3. Identify Intended Use -The intended use should be based on the expected uses of the product by the end user or consumer.'

 

Apparently some people may eat them raw as well as cooking them lightly :smile:

 

http://www.chicagotr...0,569441.column


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