13 replies to this topic

[L. Mathies]

Our company is starting a new product of breaded chicken tenders.   We will be receiving the chicken, and the breading will be received pre-mixed.  We will just be breading the chicken, packaging, and freezing through a nitrogen tunnel.  Any help for HACCP plan input such as the CCPs and concerns for micros will be appreciated

[Charles.C]

Our company is starting a new product of breaded chicken tenders.   We will be receiving the chicken, and the breading will be received pre-mixed.  We will just be breading the chicken, packaging, and freezing through a nitrogen tunnel.  Any help for HACCP plan input such as the CCPs and concerns for micros will be appreciated

 

Hi L.Mathies,

 

I deduce this is an input of raw chicken pieces and an output of raw frozen breaded chicken pieces. Correct ?

[L. Mathies]

Yes, you are correct.

[Charles.C]

Yes, you are correct.

Hi L.Mathies,

 

You may need to add a litttle more detail regarding the process details, eg chilled/frozen chicken received, breading conditions, MDs etc,,etc.

 

Plus whether any particular FS standard is intended.? This relates to Prerequisites. I assume this is routinely USDA monitored.

 

I'm not in poultry business but i daresay the consumer will take care of  any micro. aspects (eg Salmonella/Campylobacter) at cooking.

 

There are probably many generic haccp plans for this process, the meathaccp website maybe (if they do poultry as well as beef).

 

Offhand, my guess is maybe receiving (chilled/frozen?), allergens, metal, batter temp. labelling are sensitive stages.

[L. Mathies]

Thanks Charles,

[L. Mathies]

My uncertainty is where the CCP for temp control will be.  Should it be at receiving, storage, processing, and end user cooking or can some of the cold temps be justified as not being a CCP due to proper PRPs, SOPs, and use of calibrated thermometers.

[KTD]

Hi L. Mathies:

 

I assume you are currently under USDA FSIS inspection. You will have to prove you can walk on water in order to not have a CCP in this product flow. Charles is correct on the pathogens of concern.

~If the product is cold the entire process, then I would suggest a CCP of internal temp right before packaging, with a product temperature PRP throughout the process.

~If you are parfrying, then your CCP moves to right before the fryer and you have an additional CCP out of the freezer to prove you meet stabilization requirements. Easiest way to do accomplish this is using Appendix B.

~Due to repettive illnesses associated with raw breaded poultry (typically stuffed), FSIS is intensely focused on breaded products. You will have to validate your cooking instructions as meeting Lethality requirements. FSIS has an entire section of their website devoted to breaded raw poultry expectations.

~As Charles mentioned, you have the 'routine' concerns to address of FM, metal detection, allergens, etc.

 

KTD

[Charles.C]

We are working on a HACCP plan for a breaded chicken tender product.  The chicken will be received in a refrigerated state and stored until used.  It will be breaded, par-fried, and quick frozen.  The final cooking will be by the end user.   We have PRPs in place and procedure to cover adequate temp control throughout the process.  Can anyone suggest where the CCPs for time / temp should be during the process?

 

Hi L.Mathies,

 

The query seems to have been answered in Post 7 ?

 

http://www.ifsqn.com...der-haccp-plan/

 

JFI  I also noticed this USFDA comment for frozen seafood which suggests that the seafood / chicken industries may have some differences in haccp viewpoint. (Assuming the 2 processes are operationally equivalent).

 

Question: Can a single HACCP plan cover frozen, raw, breaded shrimp and frozen, parfried breaded shrimp?

Answer: Yes, one plan could ordinarily be used for both products, because the same hazards ordinarily apply to both products. Both are battered and breaded. Neither product is ready-to-eat, e.g., parfry does not result in a cooked shrimp product. For both products the hazard of Staphylococcus aureus toxin formation in the batter is reasonably likely to occur and is of concern because the toxin could survive frying by the consumer.

 

 

IMEX of precooked (= not fully cooked = equiv.raw), breaded seafood, ie non-RTE, there are no haccp, temperature-related, CCPs.

 

However,  some seafood haccp versions I have seen include temperatures for thawing of frozen input, others for core product temperature at exit freezer and others for overall-product  temperature variations.  It's all a  question of  (haccp) viewpoint which in the present  case is presumably that of  USDA.

 

PS - i noticed that the meathaccp website which seems to be regarded as "USDA-compliant" has the same CCP as in the above Post 7 for a non-frying/non-breading poultry scenario.

Edited by Charles.C, 13 December 2015 - 11:12 PM.
combined with parallel thread

[L. Mathies]

When you say right before the par frying step do you mean the breading stage (this will occur just before par frying.

Would the CCP be for a cold temp or the temp reached at par frying?

[Charles.C]

Hi L.Mathies,

 

I expect KTD will respond shortly to yr query.

 

Not my product area but I daresay the FSIS critical temperature logic is based on documents (for not fully heated/not shelf stable coated products) which are analogous to the 2 below plus the FSIS, 2015, Haccp validation publication in the last link.

 

 meathaccp - Raw Product Critical LimitTables-12.pdf   36.82KB   178 downloads

 fsis - AppendixB.pdf   71.71KB   133 downloads

 

http://www.ifsqn.com...indpost&p=89037

 

 

 

 

[KTD]

Hi L.M -

 

     You are trying to prove that the product temp did not exceed your CCP Limit during the entire 'cold side' of the process, so take the product temp immediately before entering the fryer - after batter/breading.

     I have not had a chance to delve into it yet, but was just notified that FSIS expects us to follow 318.23 (meat patty processing) for breaded poultry products that exceed 70F internally. Still trying to wrap my head around that. Appendix B still applies after the freezer.

     I still strongly recommend that you go to the FSIS website and read everything posted in their breaded par-fried poultry section. There are a huge number of expectations not outlined in the regulations due to associated illnesses over the years - including speciifc labeling requirements.

 

Charles -

     USDA FSIS regulates meat and poultry (and catfish only as of last week), while FDA has the rest - and never the twain shall meet...Although your infomation is as spot on and useful as always, we have to use caution when trying to apply FDA info/expectations/beliefs to USDA FSIS products - some are useful and others can land you in hot water. The MeatHACCP website that you posted the one article from is a very good site.

 

KTD

[L. Mathies]

I tried looking for the specific information on FSIS website but was unable to locate it.

[Charles.C]

Hi KTD,

 

I have to agree with the previous post. From a HACCP plan POV, the fsis website seems a considerable mess to me. Great collection of, afaik, obsolete haccp plans though.

 

I appreciate yr efforts. I deduce from yr post that fsis don't exactly broadcast all the finer details in the open.

 

It's unlucky that, afai could see, meathaccp don't seem to have explored this specific process variation. And surprising in view of its commercial popularity/sensitivity. Maybe it's hidden there somewhere.

[L. Mathies]

Thanks, looks like we will be meeting with a USDA inspector tomorrow to review the plan we put together, hopefully we will get everything straight then.  I will post back with an update, maybe the information can be useful to others.