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Cold Storage Limits - RTE Product


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#26 Marshenko

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Posted 27 February 2014 - 08:50 PM

yes, I had actually just come across this one as well. They are only listing 1 CCP during processing, which was my initial thoughts as well but I am still debating on whether the storage would be a CCP or if we can have a monitoring step that keeps it from being a CCP.


I promise you can. I've done it before. If you're receiving and storing at controlled temperature, unsecured temps aren't a hazard reasonably likely to occur. Slicing/handling? There are more variables involved, that's your CCP.
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#27 Marshenko

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Posted 27 February 2014 - 08:53 PM

Do you use all of the product you cook/cool immediately after hitting your second CCP? If no, do you use refrigerated storage as a CCP? I am guessing the answer to both questions is "no"


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#28 Slab

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Posted 27 February 2014 - 08:58 PM

We will be using a Sensitech TempTale 4 to monitor the ambient room temperature 24 hours a day (we can determine the increments of the readings). The room is also equipped with an alarm that will sound/call someone if the temperature exceeds its alarm point. 

 

Very good!  :thumbup:

 

 

C.botulinum in meat products other than sausage/salame products in casings?  There's a reason the FDA addresses these at length but the USDA does not.

 

Hi,Marshenko;

 

I have already admitted my ignorance to USDA guidance (I'm seafood HACCP), but I am here to learn.

Could you elaborate on the reasons (in a nut shell)?

 

Do you mean lower aw  with sausage product because of salts/preservatives?


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#29 djfitz1231

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Posted 28 February 2014 - 04:44 AM

We produce RTE sandwiches. We buy pre cooked lunch meat, slice it and then assemble, package and ship. We are USDA inspected and were told that we just need to keep the temp. under 41 degrees through out the entire process. We have no CCP step for any part of this process. We have data loggers on all of our refrigerators that record the temps. once per hour. We process in a cold room that is monitored and maintained at 40 degrees  or lower. If for some reason we need to process in a room that is warmer we follow the guidelines in the attachment that we use also use as our scientific data.


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#30 djfitz1231

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Posted 28 February 2014 - 04:48 AM

heres the attachment

Attached Files


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#31 Charles.C

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Posted 28 February 2014 - 04:49 AM

Dear djfitz,

 

Slightly OT but nonetheless thank you for the interesting post.

 

Perhaps you could share the guidelines referred in yr closing sentence, eg still zero CCPs or ?

 

Rgds / Charles.C

 

PS - above posted before i saw yr attachment. Thks.

 

I deduce this is extracted from the Wisconsin website earlier referenced ?.

 

Do you in fact include the (one) CCP/critical limits referred within yr overall HACCP system as a secondary plan.?

 

Or have you separately validated that any deviations to the original "ideal' control are always within the stated critical limits, ie there is no (risk assessed) significant hazard to address?ie still Zero CCPs. The latter type of approach is IMEX commonly applied to raw seafood processes together with temperature/time criteria issued by USFDA.

 

PPS - i am rather surprised that USDA approve processes at zero CCPs, ie technically no HACCP plan. I seem to remember that for some other meat processes there is a minimum number due to regulatory CCPs.

I am also impressed (more like amazed) that yr workers can process at 40degF. Only possible in the USA i suspect. IMEX below 10degC causes lack of hand mobility and thereby errors. Not to mention employee complaints of course.

 

@Marshenko - I apologise in advance if you think I am again making life too difficult. Based on the so far presented  maze, I think the onus is more on USDA.


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Kind Regards,

 

Charles.C


#32 Marshenko

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Posted 28 February 2014 - 02:20 PM

Charles,

 

Little bit of background:

 

The USDA only provides "examples" ... it is up to each individual plant to write their own HACCP plans and provide justification for them.  Those model HACCP plans are mostly garbage.  Provided you can back up your decision-making, a plant can pretty much do anything they want.  The USDA doesn't really have a "viewpoint" per-se, HACCP was only required in the United States for meat producers starting in 1998, so the USDA threw those model HACCP plans together to help plans get going.

 

I have done this exact process in four different facilities, and lord knows I've never had 7 CCPs or whatever it is like that USDA model HACCP plan suggests.  That borders on insanity.


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#33 Marshenko

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Posted 28 February 2014 - 02:24 PM

Also, you'll love this Charles:  according to United States regulations, sandwiches technically aren't USDA items, even if they are loaded with meat.  Sandwiches are regulated by the FDA.  However, "wraps" ARE USDA items - replace the bread with a tortilla, flatbread, lavash and roll it as opposed to making it a sandwich and it is USDA, in bread it is FDA.

 

We are messed up.


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#34 jbickle

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Posted 28 February 2014 - 03:00 PM

Charles,

 Let me start by saying, I have no food science degree. I have only 3 yrs experience as a QA Manager. Prior to that 4 yrs as a QC Tech. We have passed numerous 2nd and 3rd party audits since my being the QA Manager, 5 audits in a span of 1 1/2 months at one point, including clients, BRC, and a FSIS FSA (2 NR's, only minor, paperwork, and I never want to see that guy again!), all passed.

We call it chill/freeze because chilling as well as freezing  meets the USDA requirements for time/temperature requirements for cooling. No-one has ever questioned the fact that the freezer is not a CCP.

Our Chill/Freeze CCP follows the USDA Time/Temperature Guidelines. Temperature does not remain between 130°F and 80°F for more than 1.5 hours nor between 80°F and 40°F for more than 5 hours.  

We use the nitrogen freeze tunnel as our process according to Federal Code of Regulations Part 430.4 Alternate 2. to supress or limit the growth of L.m.

Also:

FSIS Appendix A "Compliance Guidelines for Meeting Lethality Performance Standards for Certain Meat and Poultry Products",

FSIS "Microbiological Hazard Identification Guide for Meat and Poultry Componenets Products Produced by very Small Plants",

FSIS Compliance Guidelines to Control Listeria Monocytogenes in Post-Lethality Exposed Ready-to-Eat Meat and Products"'

USDA Food Safety Information-"Fresh Pork from Farm to Table",

"Tompkins Microbiological Specifications in Food"

PHLS (Public Health leadership Society)-"Guidelines for the Microbiological quality of some RTE Foods Sampled at the Point of Sale"'

To mention a few of the resourses and scientific data we use to justify our process.

 

GMP's, sanitation, etc.

 

If I'm not answering correctly, what your're asking, that's because I don't understand the question sometimes, but I do understand why we do things the way we do, and thankfully the auditor's understand, that I know the who, what, where, when, why and how of things. Just in a laymans terms :smile:  

 

Believe me, if I had the funds to pay for further food science education, I would be first in line to sign up!  


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#35 Charles.C

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Posted 28 February 2014 - 04:25 PM

Dear Marshenko,

 

Thanks for the above clarifications.

Indeed I had more-or-less reached the assessments you mention after some browsing around the website and  recalling other previous murky episodes in the USDA past, eg

http://www.ifsqn.com...ge-2#entry68569

 

I  had mentally replaced yr “garbage” with “obsolete” inasmuch as a lot of the original guidance is useful, but the implementation is certainly not. CFIA hit the same problem and simply took all their key material down and “started” updating. USDA are apparently incapable of updating so have to rely on 3rd party websites instead. I deduce that the cryptic “reviewed by USDA/FSIS” is the current Gold Standard of approval. :smile:

 

In contrast the recent FSIS publication focused on “HACCP Validation” is IMO conceptually impressive and well-written until one reaches  the customary avoidance of an analytical comparison of target species for cooking theories.

 

@jbickle – thks for the details. Of course international terminologies will always be “lifts and elevators”. IMEX the important part is in the actual numbers and the validation of their usage. Following a recipe is fine but you need to have faith in the cookbook.

I wasn’t quite sure if you were defending USDA or not but if so, I sadly fear the train has left the station. :smile:

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C





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