12 replies to this topic

[petitloup]

hello to everyone i think i need some help with a HACCP issue in the company i work for. Well, the company is a bakery producing frozen part baked pizza bases and raw doughballs. So far, the HACCP procedure is set up to a freezing point of -15 degrees Celcium.. I know that the required freezing temperature is -18degrees Celcium determined by food law. in order to ensure my boss about the direct need to make changes in the freezing temperature limits, I need to find what s happening by law (during an audit for a certification for example) if this non conformance is found. thank you for your

[Naamfon]

Food law require - 18 C but your company set -15 C...it's mean your freezer can't set to -18 C ? many food law that set from determinate or analyses and have many reference to support for why them fixed to used - 18 C. Sure one reason it's safety .How you ensure your products safety ? I think if found during an audit maybe auditor would request the system or process be stopped and an immediate containment would be needed along with a temporary correction until resolution occurred.

[Janvm]

I had a similar situation when i started at my current employer and had a discussion about it when our veterinary inspector had some remarks about it. He stated that the average temperature of the freezer had to be -18°C minimum with a certain number of higher peaks allowed during short times. I translated this to the plant owner as a failure to deliver a product conforming to legal standard, something also coming back in the BRC standard. A lot of progress was made with simple changes in product flows and thourough training in closing doors of freezers instead of relying on plastic flaps to keep the cold in. An other part was increasing the termal mass inside the freezer by placing several IBC's with brine inside the freezer.

[Charles.C]

Dear petitloup,

Welcome to the forum!

A little more info. is relevant -

You hv not informed us for what standard you are discussing, eg is it some local Greek standard or ? If local, is it stated that freezing is a regulatory CCP or ? What kind of freezer ? Batch / continuous? IMEX, these typically run at -30degC maximum if not overloaded! or are you talking about a cold store, ie a static refrigerated space ?

The reason I ask is that traditional HACCP is unrelated to the law, it is based on your risk analysis. However some countries (rightly or wrongly) define their own regulatory CCPs / critical limits etc in which case you hv no choice.

Many people (but not 100% ) doing unconstrained HACCP (ie no regulatory CCPs) never regard freezing as a CCP. If you have a choice, I suggest you do a risk analysis and decide for yourself.

If you wish to validate what actual product core temperature must be attained for a frozen product to be considered "safe" I predict you can find justification in the literature for a maximum core value of -12degC (from memory)(practically, there is also a time factor involved). i hv previously seen -16degC used as a critical limit for a (continuous) freezing unit CCP by a pizza company (overloaded!) since this still ensured the above mentioned core temperature was attained at the exiting product.


Rgds / Charles.C

[Martinblue]

Hi Charles.C,

Is there any reference document stating critical limit should be -12c or -15C?

Edited by Martinblue, 16 August 2011 - 05:45 PM.

[Charles.C]

Hi Charles.C,

Is there any reference document stating critical limit should be -12c or -15C?

Dear Martinblue,

Yes there is but I can't remember the location offhand. If I can find a reference i will upload. The basis is not exactly rocket science i think, just generalised biochemical logic.
As a side-comment, surveyors who supervise loading of frozen foods into refrigerated transport at exits of factories in hot climates face the same dilemma, especially for IQF items. from memory, hv. seen a rule-of-thumb of around -14degC max (average)used with zero failures above a slightly higher value. Some less picky locations used to simply declare that the produce was "hard frozen" however the insurance companies were not too thrilled with such poetry.

Rgds / Charles.C

[Philip.H]

Dear petitloup,

I would like to add if you're process is not set to -18°C you are not in order with EU legislation
following 89/108/EEC law relating to quick-frozen foodstuffs for human consumption.
To call a product frozen you need to make sure -18 degrees is reached.

Cheers Phil

[Foodworker]

As Philip.H says the EU legislative limit is -18C. there are some permitted deviations up to -15 for short periods during transport.

The -12C figure only applies to temperatures in retail cabinets at point of sale.

I am not an expert, but I have never seen any convincing evidence that there is greater risk at -15 than -18.

Could it be coincidence that -18 C is equivalent in round figures to 0 F?

[Charles.C]

Dear All,

There is another thread here where I posted relevant links and also uploads (I think) and some discussion.

Sorry but don't remember the thread off-hand. The net result is that freezing manufacturers are routinely employing temps > -18degC as "critical" limits, and similarly for reception of "deep-frozen cargo".

Rgds / Charles.C

Added later - post / thread referred above here -

http://www.ifsqn.com...dpost__p__48191

As can be seen, "interpretations" are involved. Nonetheless IMEX, the usage was auditorially accepted.

[maurocon]

Dear petitloup,

I would like to add if you're process is not set to -18°C you are not in order with EU legislation
following 89/108/EEC law relating to quick-frozen foodstuffs for human consumption.
To call a product frozen you need to make sure -18 degrees is reached.

Cheers Phil

I completely agree.
The company must produce “safe and legal products” (clause 1.1.1). The voluntary production of foods that don’t fulfil the legislation is considered as a failure to comply with a Fundamental clause.
It’s completely different the situation in which there was a production of a non conforming product due to a problem. In this scenario you will have e treatment of the product, a corrective action and so on.

[Jayqc]

Although I agree with the -18 deg C, my understanding is that with regards to the quick frozen foodstuff regs these only relate to products that you are actually labelling as quick frozen

[Charles.C]

Dear All,

This is an extension of previous post.

Also not necessarily disagreeing with the comments in earlier post but the actual legal situation is not quite as straightforward as one might think.

It is true, I think, that as discussed in this forum, the freezing/storage/etc aspects of “quick-frozen foodstuffs” as given in the EC directive of 1989 have been incorporated into all ( or maybe most?) of the national legislation of member states of EU.

I don’t know about Italy but this document (2007) seems to summarize the current UK situation –

 UK quickfrozenregs1107.pdf   54.58KB   60 downloads

(Note the use of terms such as thermal stabilisation and the relevant refrigerant media).

Also note these comments in another (parallel) UK related (2007) document -

5.2 The QFF Regulations only apply to foods labelled ‘Quick Frozen’.
Trade bodies have estimated that food labelled as ‘Quick Frozen’
accounts for a maximum of 15-20% of the total Frozen Food (FF)
market (this upper percentage is estimated at approx. £862 million in
2005) . The voluntary labelling of foods as having been ‘Quick Frozen’
is generally used as a marketing/consumer information device,
although in practice it is not currently a term widely recognised by
consumers although those that do would view it as a quality indication.

5.3 The frozen food market is characterised by own label products, which
account for more than 47% of total value sales . Intelligence from
Trade Bodies suggests that only one major retailer and two major
manufacturers label their QFF as such, along with some smaller
manufacturers.

5.5 There is no legal requirement to label QFF as such, and the
requirements do not apply to frozen products that are not labelled as
QFF.

 impact assessment UK - qffeng07ria.pdf   194.6KB   49 downloads

In respect to safety, IMEX many (but not all) haccp plans do not categorise the freezing or storage steps of deep-frozen goods as CCPs. The quality aspect is a different matter of course.

Rgds / Charles.C

[BlueWinter]

Can someone please share the FDA and FSIS freezing storage regulatory reference?  I cannot seem to find anything that specifies it should be -18C/0F setting.  I know this to be the standard, but seeking to verify the regulatory reference.  Thanks so much in advance.