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Rena

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Posted 11 April 2012 - 08:53 PM

Hello,

Our plant produces RTE deli meats including dry cures, cooked and fermented products.

Recently we have reassessed our HACCP plan for dry rubbed/cured meat and moved MAP (gas flush) from CCP to CP, because it does not control pathogens (food safety), but extends the product shelf life/quality and may control spoilage organisms .We have other CCPs in product flow which control pathogens (salting, drying/aging, cooking cooling, HPP). The CFIA inspector agrees with us but we need to provide validation for this.


A CFIA database identifies the hazards below for gas flush, but I beleive they are applicable for raw products with gas flush not RTE.

  • Growth of pathogens due to inappropriate vacuum of air volume/pressure of gas (CO2) in MAP
  • Pathogenic bacterial growth with sporulating and non sporulating bacteria (Staphylococcus aureus, Salmonella spp., Escherichia coli, Listeria monocytogenes) due to time/temperature abuse if production room temperature is not maintained
  • Chemical contamination due to use wrong gas
Could you advise if these hazards are applicable for RTE deli meats, and provide a validation study or other source to prove/disapprove it?

Thank you very much,
Renata



George @ Safefood 360°

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Posted 12 April 2012 - 10:00 AM

Hi Renata,

When it comes to HACCP and more specifically the principles of HACCP the message can often be lost. This is particularly the case IMO when it comes to the prescriptive HACCP models produced by various regulatory authorities. While these models are of enormous value in assisting companies set up and develop their HACCP plans they can often conflict with the principles of HACCP as defined by CODEX.

While there may be hazards associated with certain steps e.g. MAP packing they may not always be significant - and this is the key issue. Significance. My understanding is that Modified Atmosphere Packing is designed mainly to extend shelf life i.e to retard the growth rate of spoilage micro-organisms, improve color in meats and disrupt certain chemical processes like oxidative rancidity. Put it another way, if you were depending on MAP to control a pathogenic hazard you would be in a very precarious position in regard to food safety. The modified atmosphere may well control pathogens but is incidental. Other more significant factors would be the initial microbial load of the meat, lethal kill steps and refrigerated storage.

From what you are saying you have removed MAP as a CCP and the inspector requires validation of this decision? In regards to HACCP, validation is a must for a decision to make a step a CCP. Also when a CCP is removed you certainly need to provide justification. This should be based on the HACCP team revising its hazard analysis and risk assessment which has either determined the risk as Not significant or Not a CCP based on the decision tree. The team should document the basis for the decision. MAP suppliers don't really promote it as a means of controlling pathogenic hazards so justification of your decision is easy. Verification will require more work - to find objective scientific data. Validation of the step as a CP is easier since their is a lot of reports on the impact of MAP on shelf life.

George.






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Posted 12 April 2012 - 09:17 PM

Dear Rena,

Could you advise if these hazards are applicable for RTE deli meats, and provide a validation study or other source to prove/disapprove it?


In principle this question requires a detailed knowledge / flow chart of yr process.

A related CFIA document (other than MAP aspect) is here -

http://www.inspectio...4/annexhe.shtml

Some other potential micro. hazards unmentioned in yr post are typical spore-forming ones, eg C.botulinum, C.perfringens etc. Presumably it will be necessary to demonstrate that all such potential pathogenic hazards are adequately controlled prior, during, and after packaging, particularly where residual traces could be promoted in the ROP environment, eg C.botulinum. I hv previously seen mention of MAP as assisting preventing L.mono from exceeding a specific tolerance level in the final product but this was in a refrigerated RTE meat which I expect is not yr situation. Such an interpretation is also, I suspect, not a current mainstream philosophy.

Two (USA) related publications -

Attached File  deli 101.pdf   5.11MB   80 downloads

Attached File  L.mono in RTE meat and poultry products 2006.pdf   803.5KB   51 downloads

Rgds / Charles.C

Kind Regards,

 

Charles.C


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Rena

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Posted 13 April 2012 - 03:19 PM

Hi Renata,

When it comes to HACCP and more specifically the principles of HACCP the message can often be lost. This is particularly the case IMO when it comes to the prescriptive HACCP models produced by various regulatory authorities. While these models are of enormous value in assisting companies set up and develop their HACCP plans they can often conflict with the principles of HACCP as defined by CODEX.

While there may be hazards associated with certain steps e.g. MAP packing they may not always be significant - and this is the key issue. Significance. My understanding is that Modified Atmosphere Packing is designed mainly to extend shelf life i.e to retard the growth rate of spoilage micro-organisms, improve color in meats and disrupt certain chemical processes like oxidative rancidity. Put it another way, if you were depending on MAP to control a pathogenic hazard you would be in a very precarious position in regard to food safety. The modified atmosphere may well control pathogens but is incidental. Other more significant factors would be the initial microbial load of the meat, lethal kill steps and refrigerated storage.

From what you are saying you have removed MAP as a CCP and the inspector requires validation of this decision? In regards to HACCP, validation is a must for a decision to make a step a CCP. Also when a CCP is removed you certainly need to provide justification. This should be based on the HACCP team revising its hazard analysis and risk assessment which has either determined the risk as Not significant or Not a CCP based on the decision tree. The team should document the basis for the decision. MAP suppliers don't really promote it as a means of controlling pathogenic hazards so justification of your decision is easy. Verification will require more work - to find objective scientific data. Validation of the step as a CP is easier since their is a lot of reports on the impact of MAP on shelf life.

George.

Thank you George,

We do not rely on the MAP for pathogens. There are other CCPs (salting, drying for some products cooking/cooling) to control pathogens.
But there is a conflict between a CFIA Hazard database which defines pathogen growth for gas flush step. I believe this may be applicable for gas flush used for raw meats, not for deli meats.
If we consider pathogen growth at gas flush stage it means the CCPs prior this step are not efficient. Or we need to justify from where pathogens may be introduced (equipment, contaminated gas mixture etc).
I would like to collect product without gas flush, with gas flush and packages without product but injected with gas flush and send them for pathogen testing to the laboratory plus to conduct shelf life on MAP and non MAP packed the same name products. Would it help to prove that MAP not control pathogens? Please advise.

Thansk,
Renata




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Posted 13 April 2012 - 03:26 PM

Dear Rena,



In principle this question requires a detailed knowledge / flow chart of yr process.

A related CFIA document (other than MAP aspect) is here -

http://www.inspectio...4/annexhe.shtml

Some other potential micro. hazards unmentioned in yr post are typical spore-forming ones, eg C.botulinum, C.perfringens etc. Presumably it will be necessary to demonstrate that all such potential pathogenic hazards are adequately controlled prior, during, and after packaging, particularly where residual traces could be promoted in the ROP environment, eg C.botulinum. I hv previously seen mention of MAP as assisting preventing L.mono from exceeding a specific tolerance level in the final product but this was in a refrigerated RTE meat which I expect is not yr situation. Such an interpretation is also, I suspect, not a current mainstream philosophy.

Two (USA) related publications -

Attached File  deli 101.pdf   5.11MB   80 downloads

Attached File  L.mono in RTE meat and poultry products 2006.pdf   803.5KB   51 downloads

Rgds / Charles.C


Thank you Charles,

Anaerobes are controled by nitrates/nitrites. Lm is controlled by Aw. Staph. aureus by temperature control. Thichina by freezing, salring, drying.. Oxygen removal does not minimize or destroy any pathogens. So why it should be a CCP?

Thank you Renata


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Posted 14 April 2012 - 04:38 AM

Dear Rena,

Oxygen removal does not minimize or destroy any pathogens.


As per my post, if you would like a link i will do a little searching but as i noted, your (so far largely undetailed) product/process may be relevant (eg yr L.mono comment) and possibly also yr local BCP legislation. Eg, is the finished product shelf-stable, I guess not from yr previous post? Is yr location Zero-tolerant for L.mono.?

Rgds / Charles.C

PS, Out of curiosity, i noted that you originally did have the gas-flush stage as a CCP, how did you validate that ?

PPS You may find this (gas-flush) thread interesting although it is 5yrs old and some opinions may hv changed (inc CFIA? :smile: ) - http://www.ifsqn.com...dpost__p__17495

You asked regarding validation, someone here with an equivalent (?) process may hv this information at their fingertips. However, just as an example, you might find this detailed NZFA discussion on shelf-stable, beef jerky's hazard analysis a readable starter. I expect you are already aware / have most of the kind of details they mention to hand already from a Canadian perspective.

Attached File  beef jerky, shelf stable - haccp_v2_appx-6-1.pdf   134.19KB   95 downloads

Kind Regards,

 

Charles.C


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