Hello,
I'm having some issues at present in regards to Canadian Meat Inspection Regulations and our product that we process in an area that is temperature controlled to be <10 degrees Celsius. According to those regulations, this temperature is "considered sufficient by the CFIA for the preservation of meat products for most processing activities and steps".
Now, our final product is a frozen product that has a meat filling. The meat is fully cooked, cooled, and then refrigerated before being ground/mixed with other ingredients (i.e. cheese) in the processing area. We monitor the temperatures of our fillings intermittently throughout the production day. Often times the filling is just above refrigeration temperature (i.e. 4.5 degrees Celsius), but it never exceeds ~8 degrees Celsius.
I've never seen this as an issue, and in looking at other guidelines developed in the US / EU, this is not an issue.For example, the FDA has a document available online titled "Appendix 3: Bacterial Pathogen Growth and Inactivation" that I used for reference, and our product filling is never at that temperatures between 4-10 degrees Celsius for more than 2 hours at a time.
But...are there any other opinions on this? Alternative guidance perhaps? I'm also wondering if I need to have some kind of in-plant validation completed when there is so much other regulatory guidance (outside Canadian ones) that can support that our process is safe.