Anyone out there in the applesauce making industry?? How can I justify, to an auditor, that pasteurization is not a food safety step and therefore should not be included in the HACCP plan? My understanding is that claustridium, listeria, salmonella, etc. are killed by the high acid environment, pH 4.6 or lower and 0.85 water activity. The only microorganisms of concern would be yeast and mold, with a very, very slight risk of coliforms.
Thanks for your help!!
wshirst
To add to the comments by Ian and Charles:
Guidance for Industry: The Juice HACCP Regulation - Questions & Answers
F. The 5-log Reduction Performance Standard
34. What is the 5-log pathogen reduction performance standard?
Performance standard requirements in general are goals that processors should achieve but provide flexibility on how processors accomplish them. The 5-log pathogen reduction performance standard required by the regulation means that you must treat your juice (or citrus fruit if using surface treatments) using a process that will achieve at least a 100,000 fold decrease in the number of microorganisms (see next question). Juice processors must apply controls (e.g., heat, UV light) to achieve the 5-log reduction required by the regulation.
35. Does a 5-log reduction in the bacterial plate count (i.e., aerobic plate count or total plate count) of a juice sample meet the performance standard requirement?
No. Under the rule, the 5-log reduction must be targeted to the "pertinent pathogen." The "pertinent pathogen" is the most resistant microorganism of public health concern that may occur in the juice. The pertinent pathogen may vary with the type of juice and the type of treatment used, though typically it would be Salmonella or Escherichia coli O157:H7.
36. What times and temperatures should I use to pasteurize my juice?
Precise times and temperatures depend on the type of juice you make and your process. Scientific literature is an excellent source of information. (See "Thermal Inactivation of Stationary-Phase and Acid-Adapted Escherichia coli 0157:H7, Salmonella, and Listeria moncytogenes in Fruit Juices," by Alejandro S. Mazzotta, Journal of Food Protection, 1998, Vol. 64, No. 3, 2001, pages 315-320.)
37. How can I achieve a 5-log reduction without pasteurizing the product?
You can achieve a 5-log reduction by using control measures that have been shown to be effective in reducing the number of microorganisms. You can use one control measure that has been shown to reduce the pertinent microorganism by at least 5-log (e.g., high pressure) or a combination of control measures that have a cumulative effect of a 5-log reduction. Citrus juice processors may use surface treatments of the fruit to contribute towards attaining the 5-log reduction. All other juice processors must apply the 5-log process to the juice.
Pertinent Pathogens can all survive at low pH:
Escherichia coli 0157:H7
Salmonella
Listeria moncytogenes
So the answer to your question is that you would need to demonstrate to the auditor that you can achieve a 5-log reduction by using control measures that have been shown to be effective in reducing the number of microorganisms. You can use one control measure that has been shown to reduce the pertinent microorganism by at least 5-log (e.g., high pressure) or a combination of control measures that have a cumulative effect of a 5-log reduction.
It seems to me that as you have pasteurization as part of your process and as is effective in removing the pathogens in question then it is a CCP. You could possibly argue otherwise based on studies demonstrating/validating a 5-log reduction using Aw and pH but why would you want to?
Regards,
Tony