14 replies to this topic

[Caddyshack]

Storage and Distribution HACCP, one of my customers buys, stores and sells RTE and Raw products to the food service sectors. Products remain frozen at all times, has anyone got a HACCP plan for this sort of thing so I can give him some help with what he may need to consider in his RA.

Thanks in advance

[Charles.C]

Dear caddyshack,

rather limited information perhaps ??

the short answer is that if you keep it frozen and prevent any (further) contamination, there will be no (increased) risk. Other than that it surely depends on waht you are doing to the unknown material of equally unknown origin?

Rgds Charles.C

[GuyT]

Hi Caddyshack - can't help directly with a process but can advise that a critical component will be monitoring the temperatures of the freezer units and having a focused plan for intervention - happy to chat about this area if it is of value

Storage and Distribution HACCP, one of my customers buys, stores and sells RTE and Raw products to the food service sectors. Products remain frozen at all times, has anyone got a HACCP plan for this sort of thing so I can give him some help with what he may need to consider in his RA.

Thanks in advance

[Dr Ajay Shah]

Need to provide more information before we can HELP you further. From what you have indicated If the frozen products are kept frozen then the main CCP will be monitoring frozen temperture on receipt and storage. Frozen temperature to be maintained at -18°C or below.

[Foodworker]

Here are some extracts from a fairly basic HACCP I did with a meat & poultry company that you may find helpful.

There are some omissions and there is always the debate about whether frozen storage is a CCP or not, but it may give you a starting point.

Attached Files

•  Hazard Analysis Bought In Products V5.doc   58.5KB   304 downloads
•  Pre Requisite Program Issue 5.doc   76KB   272 downloads
•  PROCESS FLOW Bought In Products V4.doc   347KB   254 downloads

[GMO]

One thing you may not have considered is a recent piece of research identified the outside of raw poultry packaging to be contaminated with bacteria:

http://www.telegraph...tudy-finds.html

To me this isn't a huge surprise as the exterior of packs undergo no cleaning process after packing, but I was surprised how common it was. I suspect some shelf stacking cross contamination? Anyway, it's worth considering that there could be cross contamination of the exterior of the packs which could be almost as dangerous for a consumer depending on how the products are handled.

It also might be worth thinking about some kind of spillage procedure?

[Foodworker]

You are right about the exterior of the packaging and the article explained the problem quite neatly.

I used to do store audits for a major C&C company and I always had problems persuading them to segregate packed ready to eat and raw frozen products. They were quite happy to seperate them if the products were chilled, but they treated frozen with a completely different mindset - packs of cooked and raw prawns touching and the same with poultry products.

Overloading of freezer compartments and poorly controlled defrost cycles meant that you often saw condensation on the outside of the packs which transferred easily between packs.

I had a micro test certificate that I used to take around with me for some external packaging swab tests which showed E.coli being picked up to help explain.

The problem never went away, mostly because the cabinet stock layouts were designed by their Head Office for commercial reasons despite food safety risks.

[Charles.C]

Dear Foodworker,

Some interesting (and brave) words.

used to do store audits for a major C&C company and I always had problems persuading them to segregate packed ready to eat and raw frozen products

What does C&C mean ? Cooked and Chilled ?

I am not surprised you had problems although it may relate to specifics. Although it is intuitively logical after (hopefully) using dedicated freezers for RTE products to then maintain the separation for the packed frozen items, i think, as you intimate, that many (most?) processors simply regard the chance of significant health risk from frozen packaged products "touching" to be negligible. And the same comment with respect to frozen storage = CCP in general. i agree some auditors do not readily accept such conclusions until (joyfully) crushed by extensive supporting references.

Other than the (FSA so far?) un-followed-up telegraph item, do you know of any published validation of these suggested fears in the literature for seafood (or any other single product for that matter)?. i cannot remember ever seeing a documented incident for seafood from this cause or any official statement spelling out a significant risk / necessity of absolute separation of frozen packaged raw / RTE seafood. [quite happy to be proven wrong though ]. If one is talking about mingling frozen packaged seafood / chicken that would be a different issue IMO (and more likely [i think] to be validatable). I hv always considered the latter scenario as a strict audit no-no thks to raw chicken's well-validated "fellow-passengers". Used to be a frequent easy rejection but less common these days (post HACCP )

Rgds / Charles.C

[Foodworker]

Morning Charles.

C&C is Cash and Carry, ie a wholesale/retail business.

I have not seen any notified problems/recalls relating to cross contamination from the exterior surfaces of packaging but the potential is clearly there.

Cooked chicken and raw chicken products are (at least should be!) processed on completely different lines, rooms and often factories, the same with cooked and raw seafoods.

Packaging (eg plastic films which is the most common UK format) in the raw factories will inevitably pick up bugs of all sorts including pathogens such as E.coli from the air, equipment and people. The bugs will be on the inside and outside of the packaging. Depending on the process, the raw chicken can be frozen before packing or frozen as a finished, packed product. The bugs will still be there.

When the products reach the store they are displayed for sale according a commercially decided planogram which dictates into which freezer cabinet the product is displayed and which products it is next to.

With chest freezers particulary, it is common to see frozen raw next to and mixed in with frozen cooked products. Occasionally there is a solid barrier, but more commonly it is an open 'mesh' type divider, or none at all. As the freezer goes through a defrost cycle and also where the product is above the load line condensation forms and can be transferred from pack to pack, partly by customers hands as they move the packs about.

I did a series of swab tests and there were occasions where I found E.coli on the outside of the frozen cooked, ready to eat, products. (Sadly this was a number of years ago and the certificates are long gone). When the packs are opened the potential to transfer to the ready to eat foods is clear.

Its another one of those areas where retailers demand extensive risk assessments and controls from processors, but food safety in their stores is secondary to their commercial interests.

A bit long winded - my apologies

[GMO]

But interesting. In stores selling to the general public (ie supermarkets) there does tend to be a solid barrier between raw and cooked IME though. Interesting that there isn't in a C&C.

[Foodworker]

I'm going to my local Morrisons in a little while, I'll do a quick audit!

[Charles.C]

Dear Foodworker,

Thks for the extended reply. I am presuming the E.coli you refer was not one of the very nasty group. (No idea probably, as is usually the case ). I am fairly confident that the genuine pathogenic content of the (raw) chicken was a much greater contamination risk than the packaging (although probably equally unknown to the typical British housewife ?).

Perhaps i can add another presentation variety to the thread - dog food separated from RTE/TV dinners by a mesh divider. I suppose it is arguable which is the higher risk ??

Rgds / Charles.C

[Foodworker]

Just returned from my supermarket visit and I have to say I was very impressed.

The dividers in the chest freezer were in most cases a plastic coated metal mesh. Where there was raw frozen next to cooked frozen the dividers were solid plastic boards. The boards even extended above the load lines.

[GMO]

Just returned from my supermarket visit and I have to say I was very impressed.

The dividers in the chest freezer were in most cases a plastic coated metal mesh. Where there was raw frozen next to cooked frozen the dividers were solid plastic boards. The boards even extended above the load lines.

Interesting foodworker eh? Now knowing UK supermarkets they won't be doing this for the joy of it, a risk assessment must have identified a cross contamination hazard which you can't really eliminate (due to the shoppers and the shelf stackers) but must be reduced by this practice.

[Simon]

Just returned from my supermarket visit and I have to say I was very impressed.

The dividers in the chest freezer were in most cases a plastic coated metal mesh. Where there was raw frozen next to cooked frozen the dividers were solid plastic boards. The boards even extended above the load lines.

Field work, I'm impressed.