6 replies to this topic

[mesophile]

Good Day,

My business is slicing/dicing cooked meats from local sources and placing in packs for end user customers. We do not cook any products on site. Our suppliers do this, they then vacuum pack the product in bulk and label with product title and use by date. These then get sent to us for processing (i.e. slicing, MAP packing, boxing, distributing).

We are have some issues at present which I would like some advice or guidance on.

Our customer needs vary considerably from day to day and sometimes when we order stock it far exceeds our customer needs therefore we are freezing the products and defrosting at a later date. This allows us to minimise wastage and ensure we can satisfy our customer needs.

We have therefore purchased a blast freezer and defrost tunnel unit in order to freeze as quickly as possible, and defrost as quickly as possible.

Unfortunately as batch to batch may change, for example day 1 cooked meat may be chilled, day 2 cooked meat may have been defrosted etc... we do not really want seperate labels for each of these products, therefore wanted to put a blanket statement on all packaging stating: "this product may have been previously frozen and defrosted under controlled conditions, can be refrozen". Our Trading Standards Officer has came back with the following comments:-

"If there is an implication that the food is fresh then there are issues surrounding the product being previously frozen. It is not common practice for sliced ham to be previously frozen and by not including this in the description of the food a consumer is likely to be misled.
It must be made clear to a consumer what the condition of the product is.
I am not happy with your suggestion to indicate that the product "may" be previously frozen. There must be a clear indication between the two types of conditions of the products.
Regulation 44 of the Food Labelling Regulations 1996 creates the offence of altering a durability date provided by the person originally responsible for marking the food. The only defence available for doing this would be to have obtained the written approval, prior to the alteration, for each batch to which you were wishing to alter the date.
It is my understanding that it is not acceptable to refreeze product which has been previously frozen. All quick frozen foodstuffs must have the statement " do not refreeze after defrosting" and even though your product is likely to fall outside the scope of a "quick frozen" product, because of the nature of your practice, I believe it could be deemed negligent not to include such a statement. "

Although they have stated "ham", it is actually all types of cooked meats we may be freezing/defrosting. Surely there are other companies in the UK and Europe that freeze and defrost meat for business needs? How would they cope with this? Can this meat be refrozen once defrosted? Are there any food safety implications regarding this? My understanding that freezing meat may simply reduce quality? Are we allowed to alter the use by dates of bulk packed products if they are not in consumer labelled packaging and we are further processing them?
Can anyone offer any help on this as this is a grey area for me.

Many Thanks

SD

[Tony-C]

Good Day,

Our Trading Standards Officer has came back with the following comments:-

"If there is an implication that the food is fresh then there are issues surrounding the product being previously frozen. It is not common practice for sliced ham to be previously frozen and by not including this in the description of the food a consumer is likely to be misled.
It must be made clear to a consumer what the condition of the product is.
I am not happy with your suggestion to indicate that the product "may" be previously frozen. There must be a clear indication between the two types of conditions of the products.
Regulation 44 of the Food Labelling Regulations 1996 creates the offence of altering a durability date provided by the person originally responsible for marking the food. The only defence available for doing this would be to have obtained the written approval, prior to the alteration, for each batch to which you were wishing to alter the date.
It is my understanding that it is not acceptable to refreeze product which has been previously frozen. All quick frozen foodstuffs must have the statement " do not refreeze after defrosting" and even though your product is likely to fall outside the scope of a "quick frozen" product, because of the nature of your practice, I believe it could be deemed negligent not to include such a statement. "
Can anyone offer any help on this as this is a grey area for me.

Many Thanks

SD

I think that you are playing with fire and that your trading standards officer has got it about right. You are lucky he/she hasn't taken you to task yet.

The "may have been previously frozen" would particularly annoy me in this situation if I was a trading standards officer.

If you want to get round this you need to do your own validation of the process and prove the durability of the product.

Regards,

Tony

[Madam A. D-tor]

Hello Mesophile,

a few questions regarding this issue:
Do your customers know and agree that the product might be frozen and defrosted?
What is the average time products are stored in freezer before defrosting?

[GMO]

The law is likely to get more strict in this area, I posted about this recently. I believe the current law is where people are likely to be misled it has to be labelled as "previously frozen" and I believe this has been mainly interpreted as around meat and fish. However, it's looking like things may be expanded.

http://www.ifsqn.com...2821#entry42821

[mesophile]

Hello Mesophile,

a few questions regarding this issue:
1. Do your customers know and agree that the product might be frozen and defrosted?
2. What is the average time products are stored in freezer before defrosting?

Thank you for your response.

To answer the questions:

1. Our customers do not at present know that the products might be frozen and defrosted. This is only something we have touched on and are looking at it for the future. I just wanted some information on this before we went fully in to is as I have never really dealt with frozen-defrosted before, especially in the cooked meat field.

2. The products may be frozen up to 6 months before being used, however this is a loose term as our supply goes up and down like a yo-yo so we may find products only frozen for a couple of weeks, and others much longer.

Thanks

SD

[Madam A. D-tor]

seems a little bit tricky to me.
IME the quality (sensory) of ham is affected when storing in the freezer.
Do you observe sensory difference between 'fresh' product and defrosted product? Have you checked this?

Besides the law issues provided by GMO, you should inform your customers about your changed sourcing. I bet that they wont like this and maybe not agree with your changed processes. Are your customers English retailers?

Is it possible to change the order and purchase processes? E.g. first have orders from your customers before you are going to purchase the product.

[GMO]

I think generally it's frowned upon to do any "may have been..." statement on packs by retailers, customers and TSOs after the whole "may contain nuts..." a*** covering exercise in the last 20 years.

IMO, there are always ways to control ordering and planning to get the result you need. If it's possible to supply sandwiches with a 2 day shelf life, it's always possible to do it.

So is it the supply which is yo-yoing or the demand? Presumably you have some control over the supply?