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Environmental Monitoring in a Bakery

Bakery FSMA Environmental Testing

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#1 PieGuy191

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Posted 26 July 2017 - 02:52 PM

Good Day Everyone,

 

I work in a small bakery that produces primarily unbaked frozen fruit, cream, and vegetable pies.  However, we do produce some baked versions of the fruit and vegetable pies and also some pies were the filling is cooked in a kettle before the shell is filled.  All of this is done in a single open room with no physical separation.  I have been trying to gather microbiological information on pies.  However, all the info I find relates to meat pies, or other bakery items such as breads, cakes, and cookies.  We consider our products to be low risk.  If you bake a pie at home and you leave on the counter, the worst that happens is it molds.  I have not found any info regarding a food borne illness outbreak related to a pie (does not include meat/poultry pies).

 

I am trying wrap my head around the FSMA requirement for Environmental Testing because they consider pies to be Ready-to-Eat.  I spent 22 years in the USDA world.  There if I did environmental zone testing and found Listeria, at some point I would have to do product testing.  

 

How are other bakeries that produce fruit/cream/vegetable pies handling this requirement?  Do I need to do a challenge study on baked/cream pies to see if they will support the growth of pathogens?  If so, does it need to be done on every flavor or can I do it by groups of like items?  These tests are expensive and the last one we had done cost nearly $10,000.  We cannot afford to do this for each item that we produce.

 

Any suggestions you have would be most appreciated. 


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#2 Charles.C

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Posted 27 July 2017 - 06:41 AM

Good Day Everyone,

 

I work in a small bakery that produces primarily unbaked frozen fruit, cream, and vegetable pies.  However, we do produce some baked versions of the fruit and vegetable pies and also some pies were the filling is cooked in a kettle before the shell is filled.  All of this is done in a single open room with no physical separation.  I have been trying to gather microbiological information on pies.  However, all the info I find relates to meat pies, or other bakery items such as breads, cakes, and cookies.  We consider our products to be low risk.  If you bake a pie at home and you leave on the counter, the worst that happens is it molds.  I have not found any info regarding a food borne illness outbreak related to a pie (does not include meat/poultry pies).

 

I am trying wrap my head around the FSMA requirement for Environmental Testing because they consider pies to be Ready-to-Eat.  I spent 22 years in the USDA world.  There if I did environmental zone testing and found Listeria, at some point I would have to do product testing.  

 

(1)How are other bakeries that produce fruit/cream/vegetable pies handling this requirement?

(2)(a) Do I need to do a challenge study on baked/cream pies to see if they will support the growth of pathogens? (2)(b) If so, does it need to be done on every flavor or can I do it by groups of like items?

 These tests are expensive and the last one we had done cost nearly $10,000.  We cannot afford to do this for each item that we produce.

 

Any suggestions you have would be most appreciated. 

 

Hi PieGuy,

 

I deduce from yr later queries that you do not have currently have an extensive haccp background.

 

I'm not in baking or FSMA area however i can make a couple of general comments.

Based on my reading many threads here "Baking" has an enormous product/process scope plus diversity of potential FS risks.

"Low Risk" has an infinity of definitions. Just like "Beauty is in the eyes of the beholder" . I'm unsure how FSMA defines it (if they do so?).

 

JF illustration, from a purely haccp POV. a product which will be subsequently "fully cooked" by the consumer is IMEX typically designated "low risk" (assumes a competent consumer). This is obviously the easiest haccp case such as pies with raw filling. Other variations can get more complicated to classify depending on regulatory viewpoints and the specific process/intended consumer use.

 

From a micro POV there are threads here with literature refs which supply some caveats to yr above FS opinion but again may relate to yr specific process. JF illustration I daresay you may be unfamiliar with the thermal resistance potentially offered by B.cereus to the baking processes.

 

Regarding my (1-2) above -

(1) I daresay other baking people here can better answer this one.

(2a-b) I very much doubt it, if you can provide suitable lit. validations of yr "environmental" GMP/process related control.


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Kind Regards,

 

Charles.C


#3 PieGuy191

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Posted 27 July 2017 - 12:10 PM

Charles, 

 

Thank you for your response.  I have 20+ years of experience writing/implementing HACCP programs.  However, my experience is all in meat/poultry.  That world I understand perfectly.  My shortfall is that I do not have a great deal of knowledge on the microbiology of baked products, specifically pies.  If I locate some good reference information to broaden my knowledge base, I would be in a better position to understand how the FSMA Environmental Testing requirement is going to affect us.

 

So any references that lead me to a better understanding of baked pie product microbiology would be great.

 

I have read your responses to other posts many times and gotten good information from them, so thank you for that.


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#4 Charles.C

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Posted 28 July 2017 - 03:42 AM

Charles, 

 

Thank you for your response.  I have 20+ years of experience writing/implementing HACCP programs.  However, my experience is all in meat/poultry.  That world I understand perfectly.  My shortfall is that I do not have a great deal of knowledge on the microbiology of baked products, specifically pies.  If I locate some good reference information to broaden my knowledge base, I would be in a better position to understand how the FSMA Environmental Testing requirement is going to affect us.

 

So any references that lead me to a better understanding of baked pie product microbiology would be great.

 

I have read your responses to other posts many times and gotten good information from them, so thank you for that.

 

Hi PieGuy,

 

I can't help much on the FSMA part because i frankly don't understand a lot of it and i am also disappointed with parts of the harpc training materials currently accessible.

 

Regarding micro/haccp aspects in the baking industry you really need a specific baking  book from the many that exist. I can probably quote you a random couple if you wish.

 

Nonetheless the threads/attachments linked below may hopefully transmit some of the FS context for baking -

 

http://www.ifsqn.com...ery-what-to-do/

 

http://www.ifsqn.com...pie-production/

 

http://www.ifsqn.com...ccp-validation/

 

http://www.ifsqn.com...ng-ccp-inquiry/

 

Attached File  bake 1 - haccp plan baked goods.pdf   1.1MB   25 downloads

Attached File  bake 2 - haccp case study - meat pie.pdf   203.38KB   14 downloads

Attached File  bake 3 - bakery products, microbial summary,Campden.pdf   115.21KB   22 downloads

Attached File  bake 4 - Baking Guide - UK hygiene regulations,1995.pdf   756.35KB   18 downloads

Attached File  bake 5 - micro.quality high risk bakery products,NZ 2007.pdf   803.45KB   24 downloads

Attached File  bake 6 - haccp in the bakery.pdf   274.96KB   20 downloads

 

PS - i just noticed this thread which may help yr EMP/FSMA query -

 

http://www.ifsqn.com...ts-in-the-fsma/


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Kind Regards,

 

Charles.C


#5 FurFarmandFork

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Posted 02 August 2017 - 08:24 PM

List of hazards FDA wants you to address in your food safety plan by commodity:

https://www.fda.gov/...A/UCM517402.pdf

 

FSIS micro specifications by commodity/process flow:

https://www.fsis.usd...pdf?MOD=AJPERES

 

 

I would assume you need to address the following:

 

Can you validate that your cooking process would remove the organisms identified as a concern in the guidance above?

What opportunity is there for contamination of your product after baking (e.g. listeria rule 2 in FSIS world)

Pathogen growth in your product isn't necessarily the issue, pathogen survival is. A positive is a positive, USA doesn't let us play quantitative micro with pathogens.

Yes, group your products by process flow and important microbial stability data like spoilage etc.

 

In a world where listeria is in heat treated frozen cookie dough, pies are certainly no lower risk and will be subject to the same scrutiny. 

 

Also, as a fellow USDA turned FDA person, be prepared for absolutely no guidance from FDA. Read warning letters and try to get into their minds, but don't expect any help.


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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 






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