10 replies to this topic

[msrcorp]

Hi All

 

I work at a sauce and mayonnaise manufacturer and we have recently taken on Pasteurised Liquid Egg alongside our Pasteurised Egg powders.  Chilled storage is not a CCP for us but I know from previous HACCP plans before I started that they had liquid egg storage listed as a CCP.  Would I need to relist this as a CCP, or could we list it as a PRP due to the egg coming in pasteurised with a COA, our Ph control and with our fridge monitoring done wirelessly. Using the camden CCP decision tree, surely this hazard is controlled by our PRP's?

 

Thanks

[VTRex]

Great question!

 

I see this as a Prerequisite Program. I'm not sure why a HARPC plan would assess that a CCP is necessary here. My guess is you have a kill step further down the line (pH below 3.3 with storage?)? That needs to be considered as well. I would like to see the reasoning for this as a CCP at this point as we do the same thing.

[FurFarmandFork]

If you're actually chilling the egg product down to refrigeration temperatures, the time/temperature limits are likely treated as a CCP. But as far as maintaining any refrigerated food in a chilled state, thats your "food storage" PRP. Failures are addressed seriously because proper cold storage is literally prerequisite to your hazard analysis. :)

 

As far as whether it would be enforced as a potential preventive control under a FSMA food safety plan...will be determined.

[Madam A. D-tor]

Dear msrcorp,

 

Whether a process step is a CCP, depends on your processes and the intended use of the finished product ( and/or raw materials).

 

Wireless monitoring of fridge temperatures does not make a control measure a PRP. It still can be categorised as CCP. However it is than a CCP that is easily controlled.

 

I disagree with VTRex that your pH control of the finished product is a killing step. Low pH is only preventing the growth of certain micro organisms.

 

So, what are you doing with the liquid egg? Is it an ingredient in emulsified sauces or in cooked sauces? Is there a pasteurisation step in the process?

[Ryan M.]

Not a CCP.  Your pre-requisite program(s) should handle the hazard.

 

I'm sure your regulatory body providing oversight has a limit and requirements?  This can be used to supplement additionally as part of your pre-requisites.

 

A CCP takes into account not only the potential severity of the hazard, but the likeliness of the hazard to occur.  How likely is pathogen outgrowth to occur given your pre-requisite programs in place?  When you assess this you should look at your company's history of temperature control and how many out of limits incidents has arisen.

 

pH can be a factor if your pH is below 4.6 since this will stave off any pathogen outgrowth if there is temperature abuse.

[msrcorp]

Thanks everyone for your help.

 

We currently buy the egg in prechilled so we are merely maintaining temperature.  We then use this within cold emulsified sauces and mayonnaise that we then control with Ph below 4.1

[VTRex]

Dear msrcorp,

 

Whether a process step is a CCP, depends on your processes and the intended use of the finished product ( and/or raw materials).

 

Wireless monitoring of fridge temperatures does not make a control measure a PRP. It still can be categorised as CCP. However it is than a CCP that is easily controlled.

 

I disagree with VTRex that your pH control of the finished product is a killing step. Low pH is only preventing the growth of certain micro organisms.

 

So, what are you doing with the liquid egg? Is it an ingredient in emulsified sauces or in cooked sauces? Is there a pasteurisation step in the process?

Hi Madam A Dtor:

A pH of <3.2 with sufficient quarantine time (temp controlled) is a kill step. You see it all the time in sauces and mayonnaise where folks don't want to use heat as a kill step. I've attached a couple of studies for you to review. 

Attached Files

•  Breidt et al Cold Fill pH 3.5 journal article.pdf   156.69KB   40 downloads
•  Breidt_research_paper_cold_fill.pdf   126.88KB   32 downloads

[Charles.C]

Hi Madam A Dtor:

A pH of <3.2 with sufficient quarantine time (temp controlled) is a kill step. You see it all the time in sauces and mayonnaise where folks don't want to use heat as a kill step. I've attached a couple of studies for you to review. 

 

Hi VTRex,

 

Not my area of expertise but for the general case, it's possibly not quite so simple as quoting a pH, eg -

 ma0.png   24.37KB   10 downloads

 ma2.png   56.18KB   3 downloads

 ma1.png   14.79KB   2 downloads

 ma3.png   18.9KB   3 downloads.

(A Regulatory CCP/PRP ?)

(Microorganisms in Foods,Vol5,2005) (the current validity of above/EC comment [if applied in UK] needs to be checked)

 

Personally I prefer to avoid the word "kill" but it certainly appears there is agreement that various pathogens when added to specified mayonnaises do not "survive". eg -

Salmonella, E. coli O157:H7, E. coli, L. monocytogenes, Staphylococcus aureus, and Yersinia enterocolitica die when inoculated into mayonnaise and dressings.

(Smittle,2000)

 

It's also unfortunately true that "does not grow" cannot automatically be equated to "does not survive", eg the US peanut disaster.

 

PS - if interested to see a variety of, apparently, common (mis?)conceptions can try this -

 

https://www.reddit.c...n_the_eggs_are/

[Charles.C]

addendum

 

I note that the above opinions may not fully match those of USFDA, eg -

 

 safety mayonnaise, sauces, pickles, dressings.pdf   810.6KB   49 downloads

[VTRex]

Hi VTRex,

 

Not my area of expertise but for the general case, it's possibly not quite so simple as quoting a pH, eg -

ma0.png

ma2.png

ma1.png

ma3.png.

(A Regulatory CCP/PRP ?)

(Microorganisms in Foods,Vol5,2005) (the current validity of above/EC comment [if applied in UK] needs to be checked)

 

Personally I prefer to avoid the word "kill" but it certainly appears there is agreement that various pathogens when added to specified mayonnaises do not "survive". eg -

(Smittle,2000)

 

It's also unfortunately true that "does not grow" cannot automatically be equated to "does not survive", eg the US peanut disaster.

 

PS - if interested to see a variety of, apparently, common (mis?)conceptions can try this -

 

https://www.reddit.c...n_the_eggs_are/

Hello Charles C.

Thank you for your reply.

I fully understand your point. Please take a moment to read (or re-read) the attachments I included. I'm sure most people on this site understand how to preserve food ("does not grow") by controlling the pH. These articles are not about that.

Best regards,

Mark

[Charles.C]

Hello Charles C.

Thank you for your reply.

I fully understand your point. Please take a moment to read (or re-read) the attachments I included. I'm sure most people on this site understand how to preserve food ("does not grow") by controlling the pH. These articles are not about that.

Best regards,

Mark

 

Hi VTRex,

 

The impressive documents in Post 7 have been previously posted on this Forum, IIRC in relation to Pickles processing. By myself.

 

I think you have possibly misunderstood my microbiological comment. It was unrelated to preservation. No problem.