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Considerations when RTE and raw beef processing in close proximity?

RTE USDA Listeria Environmental Monitoring

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#1 sjs2016

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Posted 19 February 2016 - 10:06 PM

Hi All!

 

I'm a QA/Reg Compliance Manager at a small USDA facility that processes raw beef and poultry. This is my first time posting, though i've been using this forum a lot over the past few months as I am relatively new to the food industry (spent the first 8 yrs or so after college working as an infectious disease biologist and decided I wanted to try something new and thought, hey, why not food??). I've found this forum to be extremely helpful, and i'm so glad to have found a community of people that are passionate about food safety and quality.

 

As of  now, we only process raw products, however we have been in the process of developing a RTE chicken breast. We are a fairly small facility so we have opted to contract out the cooking and processing (HPP) to another company. Presumably, the product would be returned to us after processing, sealed in a vacuum type package and we would finish back here by placing the packaged product in an outer cardboard sleeve. Has anyone had any experience with this kind of situation? I do have some RTE experience, however we cooked sliced and packaged all in the same facility so I am used to pretty stringent sanitation, monitoring procedures etc.

 

My main concern is that the RTE packaging area will have to share the same room as our Raw Beef processing room. Our current solution is to hang a large tarp in between the areas and then implement entry/exit requirements, designated handwash stations, color codes, disinfectant at barrier contact points etc. I guess my question is, would this product be considered fairly high risk, even though the actual product has already received lethality treatment and sealed before it even comes back to us? Should we be monitoring FCS more than weekly or bi-monthly? How often should we be testing the product (in addition to whatever testing procedures the processing plant performs)? Of course as QA I like to err on the side of caution but i don't want to spend money on excessive testing if we don't have to. Just wondering if anyone has any experience in a special case like this, as the USDA directives don't really have specific guidelines for my particular situation :)

 

 

anyways, sorry for the length of the post, I look forward to being an active member at IFSQN!

 

 


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#2 GMO

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Posted 22 February 2016 - 02:56 PM

I've not got experience of FDA regulations but I can tell you what risks there may be.

 

Obviously as you've identified there are a lot of potential pathogens in the raw meat, the various pathogenic E Colis would be my first thought.  In some standards / codes of practice in the UK there has been a thought that low risk (packaged) should be segregated from low risk (raw) for the above reasons but also to control cardboard and wood risk in the open food area.

 

My thought was yes, ideally you would want to segregate, people don't wash the outside of their packaging before they open it.  Why does it have to be tarp though?  Whitewall would be the way to go.  Tarp will get damaged and you will always be replacing it.  Also tricky to clean.

 

So in summary; yes I'd segregate, for two reasons:

To protect the cooked product packaging from the raw meat

To protect the open raw meat from foreign body hazards

 

It might be easier to also subcontract the final packaging stage as well.


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#3 PSC

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Posted 22 February 2016 - 03:53 PM

I work in a meat processing facility. We have dealt with this issue as our ovens are not pass through; the raw goes in and the cooked comes out of the same door. We have raw product and RTE product in the same room. We don't package in the same room, but both raw and finished are open in the same room. We are USDA and BRC Version 7 certified. We do similar things as what you are suggesting. People who touch the raw don't ever touch the finished and we have a cleaning procedure after the raw goes in the oven to sanitize any area that was touched by raw product that could be touched by people pulling the cooked product out. In my opinion, you can do it but it's not the most ideal situation. 

 

It sounds like you'll have your bases covered with what you suggested doing. If you are going to put up a barrier, which is always best (I wish we could), I would make it something a bit more permanent than just a tarp. 


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#4 sjs2016

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Posted 25 February 2016 - 03:06 PM

Thanks all for your replies!

 

GMO - According to our maintenance department, a whitewall would be impossible to install because of space constraints (area would be right up against a MAP machine) and also i believe it would partially block a drain. Wish we could, i'm not crazy about the idea of a tarp either, though our USDA inspector did say she would be ok with it!

 

I'm keeping my fingers crossed that they decide that subcontracting out the final packaging is less of a hassle than setting up the RTE area, though i'm not holding my breath :)

 

I also know that Listeria will be a micro concern, just how big of a concern i'm still trying to figure out, as technically it would not be post-lethality exposed at our plant since it's never removed from the package that it's HPP'd in. I'm hoping someone who's been in a similar situation will see the post and chime in!

 

PSC -Sounds like you and i are in a similar boat! But, if you guys are able to do it AND be BRC 7 certified, I know that it's not impossible to do.  Might have more questions that you can answer in the future!


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#5 Charles.C

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Posted 26 February 2016 - 03:25 PM

Hi sjs,

 

Thanks for the Interesting thread.

 

The BRC situation as in post 3 is noted as an RTE exception with an array of caveats in the attached file. A question of commercial pragmatism.

 

Attached File  brc6 F048 - Understanding High care and High risk.pdf   589.79KB   16 downloads

 

Additionally, the text in BRC7 Standard for high risk areas subsequent to a micro.kill treatment does include the words "uncovered[ie unprotected]" so the product in Post1 could maybe achieve another  exception.  Looks like USDA agree. I anticipate the BRC evaluation would change if the "pre-packaged" product became exposed to the environment in any way.


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Kind Regards,

 

Charles.C


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