20 replies to this topic

[TJW]

In which clause or section would the thawing/defrost of raw material (meat) be in? This is done on-site and off-site. Procedures are in place but we aren't sure which section of the BRC Standard it should be in. 4.14 Storage Facilities or 6 Process Control?

[Charles.C]

In which clause or section would the thawing/defrost of raw material (meat) be in? This is done on-site and off-site. Procedures are in place but we aren't sure which section of the BRC Standard it should be in. 4.14 Storage Facilities or 6 Process Control?

Dear tanward,

More details as to yr actual on/off site process might be useful.

I presume you have seen this BRC comment -

Certification will only apply to products that have been manufactured or prepared at the site where the audit has taken place and will include storage facilities that are under the direct control of the production-site management.

I don’t think there is any fixed layout for BRC Policies and Procedures. The only necessity AFAIK is to (somewhere) cover all applicable requirements for a specific item which appear (explicitly or implicitly) in the standard.

Personally, I always consider thawing (onsite ex frozen storage, if that is what you mean?) to be part of the overall “Process” flow. Other people may disagree ?.
Cannot see why this specific operation step would be in "Storage Facilities" which i presume is relevant to off-site variation.? Can you clarify the sequence of steps involved in Total Process ?

Unfortunately BRC loves to occasionally throw in ambiguous (aka meaningless) text, for example, what does “ critical to the quality” mean in 6.14?. I have no idea and probably neither does BRC.

Maybe i hv misunderstood yr query ?

Rgds / Charles.C

[George @ Safefood 360°]

Hi tanward

The BRC is a horizontal standard, meaning it applies across all food processes, unlike a vertical standard which applies to a specific product group or category. In this regard you will not find a specific clause which will speak about thawing of meat.

I suggest you focus on Section 6 - Process Control - 6.1 Control of Operations: This section covers how processes (including thawing) should be controlled to meet the requirements of the BRC. If thawing is a CCP in your operation then you should also focus on Section 2 - HACCP.


George

[trubertq]

In which clause or section would the thawing/defrost of raw material (meat) be in? This is done on-site and off-site. Procedures are in place but we aren't sure which section of the BRC Standard it should be in. 4.14 Storage Facilities or 6 Process Control?

My client defrosts and it's part of our HACCP plan. Therefore it is on the flow diagram, HACCP Hazard Analysis, and is a CCP in all of the processes where it is a step.

It will also come under the various other sections , like cleaning, control of operations,calibration etc... but the place to start is HACCP as it is a 'step' in your process.

[shea quay]

Would love to know the procedure that makes thawing a CCP! Even in a place I used to work where industrial microwaves were used (which were totally as amazing as they sound, by the way), I've only ever seen thawing as a process step which, as George says, is a procedure covered by 6.1. The factory procedure is probably the most important step in your case, tanward, as you have thawing occuring on and off site. I would imagine that from a product consistency and microbiological perspective it would be important that procedure would be similar in both circumstances.

[trubertq]

I could tell you but then I would have to shoot you!

It's a CCP because there is a significant risk to food safety if it isn't done properly....
Risk assessment Shea...risk assessment....I'd rather have it as a CCP and have the proper controls

Edited by trubertq, 07 March 2013 - 12:11 PM.

[MQA]

Thawing of meat? A definitely agree this is a CCP. Thawing needs to be both controlled and documented.

Also, consider your traceability... if not on the Thawing record, where else would you be recording the information of that meat (date purchased, supplier, etc)? Both records would need to coincide.

For the meat industry, the Thawing record would be one of the most important records in regards to traceability.

[Charles.C]

A couple of comments.

"meat" does not always = Meat.

Thawing is an important process to control, no doubt, but how many times have you encountered a subsequent safety-related incident due to variations ?
For (raw > raw) and (raw > cooked) frozen seafood, i have never set it as a CCP. No auditor ever queried it. Most model haccp plans just glide over it AFAIK. (Trubertq maybe won't agree, perhaps different product/species/process/experiences?.)

And similarly the 'freezing' and 'cold storage' stages.

And maybe Meat has its own viewpoint based on bad experiences.
(is it included in UK's MIG ?)

Rgds / Charles.C

[Esther]

Hello Trubertq

Not having more nformation about your process and product I agree to Charles and another member: I do not see the thawing step as a CCP although it has to be controlled. Another different thing is if this step is done under ambient temperature instead of under refrigerated temperatures.Could you tell us if your process has been certified? IF so, could ypu tell us if you has been said some comments about establishing the thawing process as a CCP? Regards

[MQA]

That’s the beauty of this forum: the vast diversity of experience and opinions.

Definitely in the sites I audit, thawing is a CCP. Too often I find it is conducted the wrong way when I first visit a site; therefore it’s definitely a CCP in my program implementations and I have never had an external auditor comment about it.

[trubertq]

My clients have a seasonal product that is cooked and frozen and then tempered back to chilled temp for dispatch.

There is no subsequent cooking step after thawing, therefore using the 2 step hazard analysis in HACCP, it has transpired that tempering ( thawing) is a CCP as there is a significant risk to food safety if the thawing process is not carried out properly, and there is no subsequent step which can control the risk.

Having it as a CCP is no big deal, I don't know people seem to be getting aerated about it to be honest, The tempering process is monitored and controlled and recorded.... which would be happening anyway. We could have it as a pre-requisite, as we have with chilling and cold storage.

It's a specific decision for a specific product in specific circumstances.

Charles, I would not presume to tell anyone what or what not to have as a CCP as I feel it is as individual as each company, I was merely sharing my experience with tanward, it is his/her decision after risk analysis whether thawing is a CCP.


Esther, we have BRC certification, it has never been raised as unusual by our Auditors ( BRC or customer) and the records have always been checked thoroughly.

We thaw under refrigerated conditions and it is controlled and recorded by data-logger but we have to record what went in, when, and when it came out again, and this does also feed into the traceability of the product through the production process.

No doubt there are some here who find this process outdated but it is what we have at the moment, the same way that we still have Blast Freezers, not all of us have access to huge wads of cash, for those new fangled spiral freezers or whatever.... cut your cloth to suit your measure... In SME's there are some stark decisions that have to be made.

.

[Charles.C]

My clients have a seasonal product that is cooked and frozen and then tempered back to chilled temp for dispatch.

There is no subsequent cooking step after thawing, therefore using the 2 step hazard analysis in HACCP, it has transpired that tempering ( thawing) is a CCP as there is a significant risk to food safety if the thawing process is not carried out properly, and there is no subsequent step which can control the risk.

Having it as a CCP is no big deal, I don't know people seem to be getting aerated about it to be honest, The tempering process is monitored and controlled and recorded.... which would be happening anyway. We could have it as a pre-requisite, as we have with chilling and cold storage.

It's a specific decision for a specific product in specific circumstances.

Charles, I would not presume to tell anyone what or what not to have as a CCP as I feel it is as individual as each company, I was merely sharing my experience with tanward, it is his/her decision after risk analysis whether thawing is a CCP.


Esther, we have BRC certification, it has never been raised as unusual by our Auditors ( BRC or customer) and the records have always been checked thoroughly.

We thaw under refrigerated conditions and it is controlled and recorded by data-logger but we have to record what went in, when, and when it came out again, and this does also feed into the traceability of the product through the production process.

No doubt there are some here who find this process outdated but it is what we have at the moment, the same way that we still have Blast Freezers, not all of us have access to huge wads of cash, for those new fangled spiral freezers or whatever.... cut your cloth to suit your measure... In SME's there are some stark decisions that have to be made.

.

Dear trubertq,

I'm sure we both agree that a HACCP plan is specific to the user's process.

It appears to me that you essentially have two time-separated processes. In yr place i would also be extremely concerned over controlling the thawing. And the next step also !.

@ Jakmqa, would be interesting to know what kind of processes you are referring to? Similar to trubertq ? My own experience is with the cooked item being directly frozen, packaged, transferred to a cold store with subsequent refrigerated (frozen) distribution. Assuming thawing was an initial process step prior to cooking, I'm curious as to what the validation for a significant risk was based on ? Unusually strict pathogenic requirements for the finished product ?

It's a pity that the OP never clarified what his process actually was.

Rgds / Charles.C

[trubertq]

Dear trubertq,

I'm sure we both agree that a HACCP plan is specific to the user's process.

It appears to me that you essentially have two time-separated processes. In yr place i would also be extremely concerned over controlling the thawing. And the next step also !.

@ Jakmqa, would be interesting to know what kind of processes you are referring to? Similar to trubertq ? My own experience is with the cooked item being directly frozen, packaged, transferred to a cold store with subsequent refrigerated (frozen) distribution. Assuming thawing was an initial process step prior to cooking, I'm curious as to what the validation for a significant risk was based on ? Unusually strict pathogenic requirements for the finished product ?

It's a pity that the OP never clarified what his process actually was.
resources
Rgds / Charles.C

Indeed Charles, It doesn't do to assume about the processes people are trying to control or the resources they have to play with.......

[MQA]

@ Jakmqa, would be interesting to know what kind of processes you are referring to? Similar to trubertq ? My own experience is with the cooked item being directly frozen, packaged, transferred to a cold store with subsequent refrigerated (frozen) distribution. Assuming thawing was an initial process step prior to cooking, I'm curious as to what the validation for a significant risk was based on ? Unusually strict pathogenic requirements for the finished product ?

Rgds / Charles.C

Yes, very similar to trubertg.

For another reason, I have walked into sites where thawing of high risk raw materials was conducted at ambient temperatures in uncontrolled environments. Education and record keeping ensured the refrigerated method was used.

The risk is pathogens. Also, the records are integral for traceability.

[Charles.C]

Dear trubertq / Jakmqa,

Interesting. By tempering i presume the meaning is "almost" thawing, ie still firm texture,?

I cannot recall ever seeing a published seafood haccp plan for the type of process to which you are referring, can you give any accessible links to one ?.
Or is this some kind of "ad hoc" arrangement for customers benefit ?. It sounds vaguely analogous to the "famous" fresh fish table occasionally seen in supermarkets but i am sure much more sophisticated.

@ Jakmqa,

For another reason, I have walked into sites where thawing of high risk raw materials was conducted at ambient temperatures in uncontrolled environments. Education and record keeping ensured the refrigerated method was used.

i assume "full" thawing is meant in above. Subsequent process unclear. I have some experience with handling batch lots of (raw) block-frozen material overnight for next day processing and usually the water temperature is self-regulating in the sense that, even in high ambient temperatures, it tends to remain very low even with agitation, eg 0-5degC, hence little microbial growth risk. I am surprised that refrigerated systems were necessary.

Or perhaps you meant that the specific observed operations were not being controlled as per the correct procedure which would not require use of a CCP. It's true that some companies nominate a CCP to emphasise some specific, known, control incapability in their own process. IMO such a logic might be acceptable as a short-term measure while a solution is sought but i don't think a CCP is a suitable response to a hazard lacking a satisfactory control measure.

Rgds / Charles.C

[George @ Safefood 360°]

I have seen thawing as a CCP during many audits in fish and meat companies. The CCP is usually expressed as the time taken for the core temp to reach a certain point. The idea is that you do not place the product in ambient conditions and allow the external temperature of the meat to increase to temperatures which will allow bacteria to grow happily while the core of the meat is still frozen. Thawing is conducted in a temperature controlled room. Sometimes it is referred to as tempering.

For me I would control it but not as a CCP.

George

[Charles.C]

Dear George,

Thawing is conducted in a temperature controlled room. Sometimes it is referred to as tempering.

Thanks for that. I deduce the net result is a fully thawed product albeit not at ambient temperature.

I previously encountered "tempering" in the high-speed cutting of frozen fish blocks for converting to breaded products like fish fingers. To protect the blades, the blocks are allowed to fractionally "warm up" in a controlled fashion but remain fully hard-frozen. I guess the (fish) usage varies.

Rgds / Charles

[MQA]

I must say I didn't expect such a keen interest for and against CCP for Thawing.

You have definitely given me something to consider in Thawing as only a CP, dependent on raw material and post processes.

But I am definitely maintaining CCP for raw materials such as egg pulp and raw meats!

This has made for excellent topic conversation when I next see our meat external auditor. I will let you know of the outcome.

[George @ Safefood 360°]

Yes Charles, I understand it to be the same. Not actually thawing but adjusting the temperature to an optimum for further processing. But I have observed it been referred as such in a number of meat companies over the years. Perhaps 'tempering' sounds more in control than 'thawing' which tends to create images of the frozen turkey on a kitchen work top.

George

Dear George,



Thanks for that. I deduce the net result is a fully thawed product albeit not at ambient temperature.

I previously encountered "tempering" in the high-speed cutting of frozen fish blocks for converting to breaded products like fish fingers. To protect the blades, the blocks are allowed to fractionally "warm up" in a controlled fashion but remain fully hard-frozen. I guess the (fish) usage varies.

Rgds / Charles

[Charles.C]

I guess this thread has once again demonstrated the extent accurate answers to (some) HACCP queries rely on a knowledge of the actual product / process involved. Sometimes a very detailed knowledge. And their specific terminologies (semantics?). Even then, it’s still often ultimately a matter of opinion (aka probability).

The thread title (which probably targetted cow, sheep or poultry meat) also included “defrosting” so perhaps the OP anticipated likely divergences of opinion.

I have limited process familiarity with above and their industries interpretation / implementation of thawing / defrosting. So further input welcome, eg to compare with next paragraph.

In seafood which I assume was the product in post #4, AFAIK, thawing has various meanings which can also vary again in subtle ways depending on whether actual processing is involved or, say, something like evaluation of net weight. The latter has been argued over both legally and conceptually for several decades but presumably only the former is relevant here. If so, IM(own)EX, thawing has at least 3 terminologies – (a) total thaw = complete removal of the ice from either block frozen or IQF (individually quick frozen) products which externally surrounds a (hard) frozen product (eg -18degC core) and continuing the process until the product texture exhibits no significant firmness “characteristic” of the frozen state. The latter is subjective and the final core temperature is usually undefined, (b) defrosting which IMEX is only applied to IQF products (and perhaps un-encased blocks) and implies removal of the external ice glaze only without changing the internal structure, ie the product maintains a firm texture characteristic of the frozen state. For small products this is often virtually impossible, regardless a very specific / careful procedure is likely to be required + subjectivity also. IMEX, the core temperature is usually again unspecified, © deglazing which is usually synonymous with (b) for IQF items but occasionally occurs as a first stage interpretation for (a).

However it would not in the least surprise me if posts / posters in this thread were using / encountering different interpretations / procedures (eg post #16) since there are no standardised terms over this AFAIK except in texts like Codex.

From a HACCP POV, (a-c) would presumably need to be carried out to avoid any significant microbial growth. For (a), at a minimum (and assuming a non-short procedure) this requires the product temperature to be “uniformly” kept low, maybe ideally 0 – 5degC, although from textbook memory, 0-10degC is not uncommon. (b) similar comments to (a) but the maximum internal temperature is maybe (just guessing) (-)5degC.
I have no direct process experience for (b) but I would expect this to be tricky indeed, again depending on the product, eg presentation size / shape / damage sensitivity. I could understand such a process involving a CCP where the raw material is already RTE (sort of analogous to all the post-cooking stages for seafood being contenders for CCPs until the freezing stage [also a CCP for some companies]).

Rgds / Charles.C

[dandy0215]

Thawing of meat? A definitely agree this is a CCP. Thawing needs to be both controlled and documented.

Also, consider your traceability... if not on the Thawing record, where else would you be recording the information of that meat (date purchased, supplier, etc)? Both records would need to coincide.

For the meat industry, the Thawing record would be one of the most important records in regards to traceability.

 

We don't have it as a CCP either.