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S. Aureus - Critical Control Point or Control Point at receiving

ingredient seafood

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#1 LoredanaM

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Posted 12 September 2014 - 09:20 PM

Product processed: stuffed seafood portion.

 

We receive in a stuffing already prepared that has as ingredients milk, cheese and the biological hazard identified is S. Aureus. The stuffing is added to salmon fillet to make a roulade that is portioned after that. The product is shipped out raw to the final customer and has to be cooked prior to consumption.

 

How far I need to go with the receiving of the stuffing in question? As it was identified in the HACCP plan, the temperature of the stuffing is taken at receiving and only if it's above 45 Fahrenheit we will contact the supplier to provide info that the product wasn't exposed more than 4 hours above 45 and never over 70. I do conduct a micro-test for S. Aureus on a quarterly basis. Is that enough due to the fact that the final product is not ready-to-eat?  

 

 

Thank you for any insight that you can provide.

 

 

 

 

 

 


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#2 RG3

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Posted 12 September 2014 - 10:41 PM

This is really based off your risk assessment.

Look at your (possible) controls in place:

  • Approved Supplier: Has a HACCP program?
  • Supplier History - no recalls, no customer complaints of illness?
  • Receiving: Temperature data trend upon arrival?
  • Receiving: COA?
  • Storage: Refrigerated? data logger?
  • Processing: Controlled refrigerated Temperature?
  • GMP's: Employees wash hands and wear gloves?
  • Product Testing: Testing of raw material trend is good?
  • Labeling: Cook before consumption is on label?
  • Product Specification: RTC

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#3 Slab

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Posted 12 September 2014 - 11:47 PM

Hi, LoredanaM;

 

I would not rely on "to be cooked" in risk assessing a control strategy as the toxin is very resilient to cooking methods found in most kitchens. Records on temperature controls is the most solid evidence to gain for this CCP at both receiving and cumulative processing times in-house. Time/temperature controls for Staph A. can be found in appendix 4 table A-2. And as RG3 has pointed out a COA would be a great addition as there may be several factors of the stuffing that could possible eliminate the hazard all together (Aw, Ph, Water Phase Salt, micro, etc).

Here is chapter 15 from the Fisheries Hazards if you do not have it for reference;

Attached File  Chapter 15 Staphylococcus aureus Toxin Formation in Hydrated Batter Mixes.pdf   1.94MB   59 downloads

 

 


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#4 Charles.C

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Posted 12 September 2014 - 11:50 PM

Dear LoredanaM,

 

No idea what a roulade is ? (aded later - appears to be =  "stuffed" :smile: )

 

Is this chilled or frozen finished product ?

 

IMO the cooking step is somewhat of a red herring since the actual hazard is SA toxin which from memory is resistant to cooking.

 

It is relevant what levels S.aureus are found in stuffing / finished product and the process temperature control/time. And the general microbiological quality.

 

Rgds / Charles.C

 

PS - posted simultaneously to previous

 

PPS - added - regarding CCP, CP etc this may depend on who the haccp plan is intended for / any regulatory factors, the ref.from Slab is typical USFDA thinking for SA control purposes although the details may relate to the food matrix


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Kind Regards,

 

Charles.C


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#5 RG3

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Posted 13 September 2014 - 01:04 AM

The cook before consumption was more for the raw salmon for Listeria species.

 

It would be a good idea to know where your supplier purchases their cheese from because if the cheese is pasteurized you may have less risk to consider. Consider the following:

 

Cheese (Cold-Packed Pasteurized Processed): VP-  Listeria  Monocytogenes SP- Clostridium botulinum

 

Cheese (Natural , Fresh , Ripened): VP; Salmonella, Listeria monocytogenes, Escherichia coli O157:H7, Staphylococcus aureus SP- Clostridium botulinum, C. perfringens, Bacillus cereus.

 

Cheese  (Pasteurized Processed): SP- Clostridium botulinum

 

Cheese   (Spray-dried): VP- Salmonella, Stphylococcus aureus, Cronobacter (Enterobacter) sakazakii Listeria  Monocytogenes SP- Clostridium botulinum, C. perfringens, Bacillus cereus

 

Bottom line: Find out how the cheese is processed and hope for a pasteurized process.

 

References:

Canadian Food Inspection Agency Reference Database for Hazard Identification.  (2008). Pg. 16-17. Downes, F. P., & Ito, K.  (Eds.).  (2001).   Compendium of Methods for the Microbiological Examination of Foods.  4th Edition.  Pgs. 555-559.  Washington D.C.:  American Public Health Association.

International Commission on Microbiological Specifications for Foods.  (2005). Microorganisms in Foods 6, 2nd Edition.  Microbial Ecology of Food Commodities.  Pgs. 467-479.  New York, New York:  Kluwer Academic/Plenum Publishers. 


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#6 Charles.C

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Posted 13 September 2014 - 10:09 AM

Dear LoreDanaM,

 

How far I need to go with the receiving of the stuffing in question?

 

Yr OP implies that you wish to know if the above step is a CCP due to S.aureus (toxin) being a significant hazard

 

Query - Is the purchased stuffing actually designated as RTE or simply "raw".? (ie Product Specification)

 

The levels of S.aureus in received ingredient/finished product should be low. Are they ?

 

Basically the general S.aureus question then becomes as per post #2, eg what is the risk that (assumed) low levels of the species in the input material may rise sufficiently to generate toxin which will resist the cooking step. ?

 

In some circumstances , eg hydrated batter mixes ( Slab's earlier attachment) process experience has demonstrated that the risk is significant thereby justifying a CCP.

 

In contrast, for typical raw seafood under usual time-temperature processing conditions the opposite logic usually holds,  notably  due to S.aureus being a poor competitor within a substantial micro.flora.

( I originally included this step as a CCP (for other microbial pathogen growth) in my early seafood haccp plans but after numerous auditors said it was unnecessary i downgraded it ).

 

Some research/searching  may be required to determine if yr matrix behaves analogously  to that in Slab's attachment or there is a known history of S.aureus problems with this style of  roulade product  ? :dunno:

(Offhand it doesn't look too significant IMO but depending on the actual SA levels / flora present / yr matrix-process conditions)

 

Rgds / Charles.C

 

PS - Apologies if you knew all the above already. :smile:


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Kind Regards,

 

Charles.C


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#7 Mike Green

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Posted 14 September 2014 - 01:20 PM

IMO as above, this is definately a 'how much have you got'? issue

 

S. aureus needs to be present in the magnitude of 10cfu/g to produce sufficient toxin to be an issue (acceptable levels in  rte soft cheese for example are something around 10- 102cfu/g

 

(S.aureus cannot produce toxin below 10celsius and is  inactivated at something like 46/47 celsius)

 

(Sorry no reference docs-as I'm not at my work computer!)

 

As suggested above by Charles-my first action would be to go back to the supplier and find out just how much S.aureus they think they are sending you(!).....and if the numbers are high enough to present a toxin issue-I'd be asking them some serious questions about their process!

 

Regards

 

Mike

 

 


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I may sound like a complete idiot...but actually there are a couple of bits missing

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#8 LoredanaM

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Posted 15 September 2014 - 03:50 PM

Dear LoreDanaM,

 

 

Yr OP implies that you wish to know if the above step is a CCP due to S.aureus (toxin) being a significant hazard

 

Query - Is the purchased stuffing actually designated as RTE or simply "raw".? (ie Product Specification)

 

The levels of S.aureus in received ingredient/finished product should be low. Are they ?

 

Basically the general S.aureus question then becomes as per post #2, eg what is the risk that (assumed) low levels of the species in the input material may rise sufficiently to generate toxin which will resist the cooking step. ?

 

In some circumstances , eg hydrated batter mixes ( Slab's earlier attachment) process experience has demonstrated that the risk is significant thereby justifying a CCP.

 

In contrast, for typical raw seafood under usual time-temperature processing conditions the opposite logic usually holds,  notably  due to S.aureus being a poor competitor within a substantial micro.flora.

( I originally included this step as a CCP (for other microbial pathogen growth) in my early seafood haccp plans but after numerous auditors said it was unnecessary i downgraded it ).

 

Some research/searching  may be required to determine if yr matrix behaves analogously  to that in Slab's attachment or there is a known history of S.aureus problems with this style of  roulade product  ? :dunno:

(Offhand it doesn't look too significant IMO but depending on the actual SA levels / flora present / yr matrix-process conditions)

 

Rgds / Charles.C

 

PS - Apologies if you knew all the above already. :smile:

 

Charles, this batter mix it is used as an ingredient that it is not RTE - the end consumer has to cook the final product.

 

I do run micro-tests for the stuffing on a quarterly basis and so far everything came back <10 CFU/gr.

 

 

My issue is if I need to require the supplier ( as answer for an earlier reply there is a supplier approval program) to send a TTi with each transport and include the TTi as CCP at receiving step.

 

Regards,

 

Loredana


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#9 LoredanaM

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Posted 15 September 2014 - 03:53 PM

IMO as above, this is definately a 'how much have you got'? issue

 

S. aureus needs to be present in the magnitude of 10cfu/g to produce sufficient toxin to be an issue (acceptable levels in  rte soft cheese for example are something around 10- 102cfu/g

 

(S.aureus cannot produce toxin below 10celsius and is  inactivated at something like 46/47 celsius)

 

(Sorry no reference docs-as I'm not at my work computer!)

 

As suggested above by Charles-my first action would be to go back to the supplier and find out just how much S.aureus they think they are sending you(!).....and if the numbers are high enough to present a toxin issue-I'd be asking them some serious questions about their process!

 

Regards

 

Mike

 

 

Where the stuffing is stored and introduced in the process the temperatures are under <45 F; thus under 50F which seems to be the critical limit. The stuffing is tested on quarterly basis by a third-party lab and so far all tests came back <10CFU/gr.

 

Regards,

 

Loredana


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#10 LoredanaM

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Posted 15 September 2014 - 04:02 PM

 

This is really based off your risk assessment.

Look at your (possible) controls in place:

  • Approved Supplier: Has a HACCP program?
  • Supplier History - no recalls, no customer complaints of illness?
  • Receiving: Temperature data trend upon arrival?
  • Receiving: COA?
  • Storage: Refrigerated? data logger?
  • Processing: Controlled refrigerated Temperature?
  • GMP's: Employees wash hands and wear gloves?
  • Product Testing: Testing of raw material trend is good?
  • Labeling: Cook before consumption is on label?
  • Product Specification: RTC

 

The supplier is SQF certified - based on my experience with SQF they are very stringent about processes. There were no recalls and no customer complaints as far as I am aware.

 

For receiving in my company HACCP plan there is a temperature at receiving, but no data logger (the supplier requires now that all shipments to us should have the TTi sent too) - my question at this step is if I have to include the checking of the TTi as a CCP?

 

Storage and processing temperatures: digital temperature recorder with chart.

 

Raw material testing ( stuffing): done on a quarterly basis (so far all tests came back with <10 CFU/gr).

 

Regards,

 

Loredana


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#11 Charles.C

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Posted 15 September 2014 - 05:05 PM

Dear LoredanaM,

 

The required raw material/ingredient conditions and associated sampling at receiving (based on FS logic, etc) should be stated in yr agreed specifications.

From a purely temperature POV, I would have thought that yr finding  a result exceeding an agreed maximum value would involve rejection for many receivers. Correlation to a satisfactory TTi record (I presume this means transport data logger ?), etc may be "problematic".

The supplier should be qualified as an “Approved Supplier”, based on customary procedures. This then implies that you have "confidence" in his product/process/hygiene, etc.

 

Assuming the above is possible and perhaps depending  on yr  FS standard involved (if any), many processor  haccp plans choose to designate the receiving step as a PRP. Based on yr posts, the SA data at receiving seems compatible with such.

Some FS standards define any additional documentation/tests required at receiving. ?

 

Regardless of the above, the subsequent hazard analysis depends on your own process/controls of course. And the finished product usage.

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


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#12 LoredanaM

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Posted 17 September 2014 - 08:54 PM

Dear LoredanaM,

 

The required raw material/ingredient conditions and associated sampling at receiving (based on FS logic, etc) should be stated in yr agreed specifications.

From a purely temperature POV, I would have thought that yr finding  a result exceeding an agreed maximum value would involve rejection for many receivers. Correlation to a satisfactory TTi record (I presume this means transport data logger ?), etc may be "problematic".

The supplier should be qualified as an “Approved Supplier”, based on customary procedures. This then implies that you have "confidence" in his product/process/hygiene, etc.

 

Assuming the above is possible and perhaps depending  on yr  FS standard involved (if any), many processor  haccp plans choose to designate the receiving step as a PRP. Based on yr posts, the SA data at receiving seems compatible with such.

Some FS standards define any additional documentation/tests required at receiving. ?

 

Regardless of the above, the subsequent hazard analysis depends on your own process/controls of course. And the finished product usage.

 

Rgds / Charles.C

 

Through our Approved Supplier program the supplier was approved (both companied have been working together for more than 5 years and as mentioned above the supplier didn't have a recall thus far). The process is actually pretty simple: the stuffing is applied to the fish, the combination is rolled resulting in the stuffing being in the center of the portion. The portion is inserted in a wax paper and shipped to the client, with "to be cooked" intended use.

 

So, basically, just using the TTi at receiving and checking the temperature of the product upon receiving doesn't seem to be the proper preventive measure; maybe I am becoming too much FS driven.


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#13 LoredanaM

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Posted 17 September 2014 - 08:56 PM

I want to thank you all for your help in this matter - it gave me a different perspective in how to look at the process.


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