13 replies to this topic

[urbani]

Hi there, I own and work in a food manufacturing company and we produce a Ready-to-Cook product line. It's a very simple Italian rice appetizer. My thought process is telling me that we really have no critical controls to meet, solely quality points - no temperature requirements, a few physical hazards, and minor biological hazards that affect quality rather than safety. If this is the case, will I have a very simple CCP section, and more of a Quality Control section? I'm worried because I feel as though I'm missing something and it will stop us from going SQF Level 2 - hopefully Level 3 when all said and done.

Let me know what you think.

Thanks,
J

[Marshenko]

I'm gonna steal Charles's line and say that it might help if we knew a little more about your process, i.e. ingredients, product flow, etc. How is this product actually made?

[urbani]

I'm gonna steal Charles's line and say that it might help if we knew a little more about your process, i.e. ingredients, product flow, etc. How is this product actually made?

You're right, I should have provided more info! We manufacture Italian risotto, cooked in a kettle with water and chicken stock. Different varieties of risotto include vegetables added in, or porcini mushrooms. It is then cooled on bakery trays in a cooler. We then run it through an encrusting machine, batter/breader, finally flash fried and frozen on bakery trays. It is hand bagged and boxed. It is sold to retail stores. Shelf life 18 months @ -18C.

I realize there are some allergens in our ingredients, but there is no cross contamination as we stagger production days, and all of them contain the same base ingredients/allergens.

Let me know if I can clarify anything else!

[john123]

If your product is consumed uncooked, does it have the potential to cause harm? (i.e. I take your product out of my fridge, don't cook it sufficiently, then eat it). I've heard of a past recall of chicken pot pies, it stemmed from a construction worker taking the frozen pie to work and leaving it on the dash of his truck until lunch time. He used the sun to warm the pie and then he ate it, but his "cooking" didn't achieve the required temperature and it made him sick.

I'm not in the RTC business, but I always see messages like "Cook thoroughly" or "Cook before eating" on some of the items I use at home, and I've seen others refer to that printing as a CCP. If your product requires cooking as a final kill step, then it should be on the package.


I'm curious what physical and biological hazards you've identified that are only "quality" related, if you don't mind sharing.

[Marshenko]

That sounds RTE to me, but even if you're intending it as RTC with validated cooking instructions and safe handling directions, I can only assume that cooking and cooling are going to be your CCPs, since at very least you've got bacillus cereus which will form spores and release toxins if heated and cooled inappropriately.

http://www.foodsafet...ore_Forming.pdf

Someone else is going to much better than I am though.

Edited by Marshenko, 26 April 2013 - 07:01 PM.

[urbani]

John and Marshenko:

The product is technically RTE off the line, however, it needs to be cooked in an oven @425F for 17 minutes to get the experience of the end product, and because we do not market or sell it as RTE. Our packaging has KEEP FROZEN and COOKING INSTRUCTIONS labelled.

Off the line, there are no hazards as it is fully cooked risotto, balled and fried. There are no temperature points during these stages that we need to meet for killing any bacteria as it is boiled for 20 minutes then flash fried after cooling. And again, it is a RTC product with instructions.

This is where I start to over-think things, as the Risotto is fully cooked in a kettle, then formed, batter/breaded and flash fried. At almost all stages it IS ready to eat, however we do not market or sell it as that. Do I need to mark down that we measure temperatures, adding in an extra step, as there is no need to? Or just leave this out of the HACCP plan altogether?

The main physical hazards I can think of would be metal pieces, but we metal detect the product, and the machines have very little moving parts. Other than that, if it occurs, plastic bag or paper bag fragments. I would assume that is more of a quality issue?

The Biological hazards we have identified are weevils in rice which are rare, but may occur - we stem this by keeping the rice in the cooler.

Thank you for the replies!

[Charles.C]

John and Marshenko:

The product is technically RTE off the line, however, it needs to be cooked in an oven @425F for 17 minutes to get the experience of the end product, and because we do not market or sell it as RTE. Our packaging has KEEP FROZEN and COOKING INSTRUCTIONS labelled.

Off the line, there are no hazards as it is fully cooked risotto, balled and fried. There are no temperature points during these stages that we need to meet for killing any bacteria as it is boiled for 20 minutes then flash fried after cooling. And again, it is a RTC product with instructions.

This is where I start to over-think things, as the Risotto is fully cooked in a kettle, then formed, batter/breaded and flash fried. At almost all stages it IS ready to eat, however we do not market or sell it as that. Do I need to mark down that we measure temperatures, adding in an extra step, as there is no need to? Or just leave this out of the HACCP plan altogether?

The main physical hazards I can think of would be metal pieces, but we metal detect the product, and the machines have very little moving parts. Other than that, if it occurs, plastic bag or paper bag fragments. I would assume that is more of a quality issue?

The Biological hazards we have identified are weevils in rice which are rare, but may occur - we stem this by keeping the rice in the cooler.

Thank you for the replies!

Dear oldschool,

As a starter, you might like to peruse this parallel thread which mainly deals with US, non-ready-to-eat (NRTE) (ie RTC) beef / poultry products.

http://www.ifsqn.com...dpost__p__60297

The obvious query is why do you market it as RTC ? (I'm actually surprised that 17mins at 425degF does not ruin a RTE item?)

Is the NRTE status of yr product officially validated ? I'm not in US but AFAIK, the product status there is regulatory controlled depending solely on the process.ie RTE = RTE.

According to above logic, the haccp plan CCPs will solely follow the process objectives, not yr "labelling".

If Canada the same as US, CCPs will therefore probably include the "cooking" step, metal inclusion, batter control, maybe labelling for allergens depending on yr prescribed haccp format (CFIA?). (added) - And maybe ingredients (?) if chemicals involved.

No doubt Canadian posters here have better knowledge on the above.
Rgds / Charles.C

[esquef]

Just a couple of things to consider re. SQF and HACCP:

You say that the product and cooled and that it has a shelf life of 18 months @ -18C. I'm assuming that you're also freezing the product. I'd have to think that if there are "minor biological hazards " with your ingredients you'd need to monitor your cooling and freezing temps as a CCP. Also, while overcooking you product would be a quality issue, undercooking may be a food safety issue depending on your ingredients and the potential need for a kill step.

As for allergens, if you have SKUs with different allergens SQF has fairly strict allergen control requirements. Just by running one product in a day isn't going to prevent allergen cross contamination. It may reduce the chances since you don't have to worry about airborne cross contamination, but if you have allergen protein for a product that, let's say contains egg, and if you run the next day a product that has whey but no egg, you'll need to validate and verify your cleaning of food contact surfaces in order to be compliant with SQF Level 2.

As for labeling, I'm not famiar with Canidian regulatory issues, but in the U.S. we have the FSIS (Food Safety and Inspection Service, a branch of the USDA) which tests products off the shelf for microbiological pathogens and for allergens in the product but not on the label. A good percentage of food recalls here are a result of mislabeling, and many of them are due to inadverdent cross contamination.

Good Luck,
esquef

[john123]

Off the line, there are no hazards as it is fully cooked risotto, balled and fried. There are no temperature points during these stages that we need to meet for killing any bacteria as it is boiled for 20 minutes then flash fried after cooling. And again, it is a RTC product with instructions.

This is where I start to over-think things, as the Risotto is fully cooked in a kettle, then formed, batter/breaded and flash fried. At almost all stages it IS ready to eat, however we do not market or sell it as that. Do I need to mark down that we measure temperatures, adding in an extra step, as there is no need to? Or just leave this out of the HACCP plan altogether?

My inexperience may show here, so take my comments in context as someone who doesn't deal with RTE/RTC in his facility. But when you say "There are no hazards" because it was boiled for 20 minutes, that right there sounds like a possible CCP to me because you make it sound like a kill step. Meaning, if your boiling step fails, there is a risk of micro contamination down the line. Have you verified the 20 minutes is sufficient (micro test history should be sufficient)? Are you verifying it actually boils for the full 20 minutes? Can you tell if someone shut the machine down early and didn't fully complete the kill step?

The main physical hazards I can think of would be metal pieces, but we metal detect the product, and the machines have very little moving parts. Other than that, if it occurs, plastic bag or paper bag fragments. I would assume that is more of a quality issue?

Absolutely it can be a safety issue. The US FDA has 7-25mm called out as a possible choking hazard, so if you expose any FM in that size range it's a concern. Anything hard or sharp under that size can still break teeth or cause cuts.

With all that said, you have to assess whether or not it is likely to occur and whether or not it would be a significant hazard, and it will be specific to your process. If you're metal detecting because there's a chance your machine could start throwing off metal and you wouldn't otherwise know it, could be significant, could make your MD a CCP.

Your plastic and paper bag fragments sound unlikely from your statement, but it's a good idea to make sure employees are trained to watch for torn and ripped packaging.

Edited by john123, 30 April 2013 - 06:44 PM.

[Pizza&Sandwich]

You're right, I should have provided more info! We manufacture Italian risotto, cooked in a kettle with water and chicken stock. Different varieties of risotto include vegetables added in, or porcini mushrooms. It is then cooled on bakery trays in a cooler. We then run it through an encrusting machine, batter/breader, finally flash fried and frozen on bakery trays. It is hand bagged and boxed. It is sold to retail stores. Shelf life 18 months @ -18C.

I realize there are some allergens in our ingredients, but there is no cross contamination as we stagger production days, and all of them contain the same base ingredients/allergens.

Let me know if I can clarify anything else!

What does the consumer do to "cook" the product?

In the US, microwaving is not a kill step. We produce fully cooked frozen sandwiches (think McDonald's breakfast), but I would never eat one off the line or frozen (quality). They are considered RTE because they do not undergo a kill step again.

[Charles.C]

Dear All,

It’s a sort of interesting topic IMO. The options will surely overlap regulatory food safety controls / labelling / specific products / specific locations ?.

IMO a finished product is either designated / processed to be RTE or not, with documentation to match. After a re-reading, perhaps my earlier post was unfairly suspicious but the manouevres which seem to currently be being implemented regarding implied RTE / NRTE product status have a distinctly questionable (haccp) FS basis to my mind and also with respect to the final consumer.

However it is well documented and not illogical that some validated RTE products may acceptably be labeled with heating recommendations. After all, it is rather unusual to eat frozen RTE product direct from the package (although there is absolutely no reason why they should be taking any risk in doing so since the frozen product is designated RTE, eg the popular “cocktail shrimp”). The legal interpretation of labeled “cooking” instructions regarding implied status of the product as RTE/NRTE, ie with respect to FS, appears to occasionally be a “grey” area. And capable of causing consumer errors. The worst case scenario from a FS viewpoint is presumably where truly RTC products are mistakenly believed to be RTE.

The OP posed ( with SQF intentions) queries regarding the significant hazards to be controlled in the haccp plan. Theoretically. AFAIK, the haccp plan is obliged to be based on the (initially) specified classification of the finished product / process-flowchart details. However, if the plan is only intended for the personal use of the designer, they can presumably regard the classification of the finished product as they wish and act accordingly. However, I would expect that haccp plans presented for certification / audit purposes are likely to be a “different ball game” , eg as 2nd paragraph above. Closely followed by labeling regulations.

Having said all the above, based on the supplied process description, especially the final stages, I am not yet convinced that the product is anyway RTE.

@Lacey

What does the consumer do to "cook" the product?

See top post 6. The net weight is unspecified but my own initial reaction was that this instruction more suggests a NRTE-RTC product. Unless it’s a 2kg pack (US standard i understand)?.

In the US, microwaving is not a kill step. We produce fully cooked frozen sandwiches (think McDonald's breakfast), but I would never eat one off the line or frozen (quality). They are considered RTE because they do not undergo a kill step again.

I deduce you mean that you have no reservations off-the-line/frozen regarding FS. Good to know.
Perhaps slightly more reassuring to say “ …do not need to undergo …..”

Rgds / Charles.C

[urbani]

Everyone, thank you for the replies.  I've been talking to a consultant we used to work with, and we've been sorting it all out.  I've been making things more complicated than need be.  I have to keep in mind "write what you do, and do what you write" haha, it's tough, but my mind gets me carried away.

 

I'll keep posted if anything else comes up.

 

I really appreciate all the help!

[Charles.C]

Everyone, thank you for the replies.  I've been talking to a consultant we used to work with, and we've been sorting it all out.  I've been making things more complicated than need be.  I have to keep in mind "write what you do, and do what you write" haha, it's tough, but my mind gets me carried away.

 

I'll keep posted if anything else comes up.

 

I really appreciate all the help!

Dear oldschool,

 

"write what you do, and do what you write"

 

In some situations, this can be a euphemism for "making it up as one goes along"

 

Anyway, good to know that you have got somewhere.

 

Rgds / Charles.C

[urbani]

Dear oldschool,

 

"write what you do, and do what you write"

 

In some situations, this can be a euphemism for "making it up as one goes along"

 

Anyway, good to know that you have got somewhere.

 

Rgds / Charles.C

 

 

I completely agree, I have to sort out the technical side first, but keep in mind that the process steps are laid out straightforward; rather than getting carried away with too many tangents.  haha