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Posted 11 May 2018 - 04:04 PM

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. 



Scampi

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Posted 11 May 2018 - 05:00 PM

do you have an inspector on site, or are you spot inspected?


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Posted 11 May 2018 - 05:17 PM

CFIA will require a validation is you are going to run your processing room at above 10C. This will be just as important once SFCR are implemented.

 

The onsite validation can include supporting whitepapers based on scientific data but MUST include site specific data. You need to invest in some dataloggers (wireless ones are relatively inexpensive and you will use them alot once you have them) and perform a WORST CASE scenario on your product(s) including product sitting for xx amount of time due to mechanical breakdown etc.

 

One more thing to consider, is running outside micro on your product that has been above 6C for set intervals of time (1/2 hour, hour, etc) to map the growth. 

 

Then you put those 2 data sets together and voila you have what you need. When it comes to meat and CFIA you cannot be too careful

 

You may have a little more wiggle room with SFCR as Tom Graham (CFIA) had said at the food safety forum in 2016, that he'd been in a pack house where the room temp was 74F with zero impact on food safety


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Posted 11 May 2018 - 05:43 PM

Thanks for the responses. 

 

We have a CFIA Inspector on-site. But let's say that it's been over a decade and now this is a problem...

 

We are not looking at running the processing room >10C. The issue is that apparently our in-process ingredients need to stay <4C if we pull them from the refrigerator...obviously this is impossible once we mix with a non-refrigerated ingredient.

 

But yes, Scampi - it seems that they are looking for us to provide site specific data, so you may very well be right about course of action.



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Posted 11 May 2018 - 06:15 PM

I'm sorry to say but i'm not surprised it's taken them 10 years to bring this up....that's the MO of them (my background is meat) Seems to be whatever the training was focused on OR when an inspector gets their wrist slapped for letting something slide at one location......every other establishment pays the price 

 

I would also suggest that if you're not BRC/SQF certified as yet, but probably will be in future, this will be something they ask for as well so I would start it now just the same.

 

I had to do a similar validation but on the blast freezer---product was tiny little birds and they wouldn't let us pack prior to chilling (everything sold frozen) even though you could physically show them a rock solid bird after 40 minutes......it took me a month to put all the data together and another 6 months for them to give me the ok (VIC went off on leave and the fill ins didn't want to touch it)


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Posted 15 May 2018 - 04:16 PM

Well, I'm looking at how to approach this validation study, and I'm wondering if anyone knows of any PMPs (pathogen modelling programs) that would actually allow me to predict growth in temperature ranges of 4°C  to <10°C? The ones I've seen start at 10°C.

 

My issue with tackling a worst-case scenario type of validation study is that I don't have any method of maintaining my filling temperature at, say, 8°C. In processing, temperatures fluctuate depending on how much/how little the ingredients are being handled. It could be 4.5°C  for 1 hour, 6.4°C  for 30 minutes, 5.0°C  for the next hour, etc. 

 

What I'm thinking of doing is simply sending the product for microbial testing as per regular production methods that is 5 hours at most, and backing it up with white papers that indicate that under 10°C  there isn't going to be pathogen growth jeopardizing food safety unless we're leaving it at that temperature for something like 2 days.  It is also a NRTE product..

 

Any input would be appreciated. We're a small business, so we have very limited resources. 



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Posted 15 May 2018 - 07:09 PM

Some of the FSIS models go under 10ºc

https://pmp.errc.ars...aspx?ModelID=24

 

FDA's growth/toxin formation temperature guidelines may help? Table 3-B of this document has time temp combinations for various pathogens.

 

https://www.fda.gov/...A/UCM517405.pdf


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Posted 15 May 2018 - 07:35 PM

Thanks FurFarmandFork! I've actually looked over both of those already and I do think the FDA's guidelines are very helpful, but the PMPs aren't really applicable for my situation. I know those are the most commonly used ones though. 



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Posted 15 May 2018 - 08:03 PM

Perhaps these will help with the PMP

 

http://www.combase.c...ex.php/en/tools

 

http://www.meathaccp...ling/therm.html

 

http://mrviewer.info/

 

http://www.combase.c...ex.php/en/tools

 

I will tell you that I have never held meat products above 6C for any length of time........if the ingredient got to say 5.5 it would go back into the cooler to chill down before being used again.  Perhaps what you could do is send a sample of your filling to the lab, and asks them to hold and grow for you. You could then send them frozen samples and they can adjust the hold temperature and then plate and grow so you can then plot that information.............I know we always have to worry about $$$ and certainly don't want to spend any when we don't have too.

 

At PP, sister location would reject the load if our raw material was 6.0 or higher as they would lose 1 full day of shelf life for each 0.5C higher 


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Posted 15 May 2018 - 08:39 PM

4.2.1.2 Environmental Temperature Conditions Meat Inspection Regulations, 1990 (MIR):

36. The temperature in a room or area of a registered establishment where a meat product is processed, packaged, labelled or handled shall be appropriate to ensure the preservation of a meat product.

The required outcome is to control the growth of microorganisms in the room or area used for the processing, packaging, labelling or handling of meat products. Room or area temperatures must also ensure control of product temperature during processing activities, such that there is no increase in bacterial growth of the product that would affect the validation of any further lethality step or validation of product shelf life.

The operator's written control program must justify the room or area temperature most appropriate for the specific processing step conducted therein, specifying hazards related to temperature abuse in the establishment HACCPsystem. Historically, a room temperature of 10°C has been considered sufficient by the CFIA for the preservation of meat products for most processing activities and steps. Alternative temperature control measures must provide the same or better outcome.

Where processing equipment, such as automated grinding, mechanical separation and other comminuting procedures, produce enough heat that could warm up the product's internal temperature significantly, the specific hazard for temperature abuse must be accounted for in the operator's HACCP system.


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Posted 15 May 2018 - 10:26 PM

Thanks again for the info Scampi. I'm going to be looking at those models, and certainly the hold and grow option will be an option to consider as well. Another colleague I spoke to mentioned that they simply left their raw, ground beef that had been further processed, out for 8 hours in a room that was 10 degrees Celsius and sent it for a standard plate count. The count was then compared to just the raw, refrigerated ground sample. It sounds similar to our situation except that our beef has already undergone lethality.

 

I'm hoping that'll work in our situation, but it's still a WIP.





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