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Hazard Analysis on Ambient Room Temperature


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#1 ashleysidney

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Posted 28 August 2013 - 04:05 PM

Hi,

 

Can anybody help, we had an audit a number of weeks back and recieved an N/C for not having a hazard anaysis and or risk assessment completed on the room temperature where we pack our product.

 

We pack fresh shellfish, and in the summer the temperature can reach maybe 15-18 degrees celcius.

 

Basically I need to proove to the auditor we dont need to reduce the temperature (ie have the girls packing in a chilling unit) in the packaging area. I complete temperature checks on the product but not on the room temperature...

 

We have a fast turn over of the product and once its packed we place it directly into the chill! (in saying that occasionally the temperature does rise above 5)

 

Has anybody ever come across this issue or have any advice! If there is risk assessment or hazard analysis all ready completed it would be really appreciated!

 

Thanks a million in advance

 

 



#2 Charles.C

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Posted 28 August 2013 - 07:31 PM

Dear ashleysidney,

 

You omitted to mention what the perceived hazard was.

 

i presume the criticism was microbial growth due to prolonged "high' temperature exposure.

 

In fact, for various typical pathogens,  USFDA have published a table listing maximum overall safe time to leave seafood exposed to a range of temperatures while processing, going up to at least 21degC in steps.

If that is what you are seeking, the info is given in famous USFDA publication titled approx. Fish, Fishery Hazards Guide, ed.4 ca 2010. Freely downloadable.

 

Rgds / Charles.C

 

PS - nonetheless, the general recommendation is, as you say, to maintain core temp. below 5degC. Not too easy when handling of course. even more so in tropical conditions.

 

PPS - maybe i misunderstood yr process. I assumed final product is frozen. Perhaps not ??


Kind Regards,

 

Charles.C


#3 Mathieu Colmant

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Posted 28 August 2013 - 09:43 PM

Hi,

 

I think that every time you get a NC, you have to ask the basis of the NC. Is it a regulation, national or European, any standard,... ?

It can help you to find if the NC is adequate (Auditors, too, can make mistakes) and how to solve it.

 

On this case, I think that the risk analysis must be made on the product. The temperature of the product is important, room temperature is just a tool to satisfy to the limit.

 

You can also note that I don't use the term "core temperature". When you eat a product, you eat all of eat, not just the core. Core temperature is used to check the refrigeration and cooking processes : If the core have an adequate temperature, all of the product must have, logically, the adequate temperature too.

 

Regards,

 

Mathieu Colmant

VeilleAlim.eu


Mathieu Colmant

Consultant in Food Safety - Brussels & London

Director

FollowFoodLaw.eu ltd


#4 Charles.C

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Posted 29 August 2013 - 03:13 AM

Dear VeilleAlim,

 

On this case, I think that the risk analysis must be made on the product. The temperature of the product is important, room temperature is just a tool to satisfy to the limit.

 

I agree but In fact many (most?) processors use ice to maintain cold chain. But not I suspect in this particular product / process step case. So maybe room temperature has more than usual influence.

(legally, i believe UK also places minimum limits on temperature in the work place [18degC ?] unless adequately attired/special function.)

 

You can also note that I don't use the term "core temperature". When you eat a product, you eat all of eat, not just the core. Core temperature is used to check the refrigeration and cooking processes : If the core have an adequate temperature, all of the product must have, logically, the adequate temperature too.

 

 

My choice of "core" was primarily aimed at microbiological POVs. IMEX this is the customary preference. I daresay the OP intended the same although I agree the text was unspecific. As far as eating is concerned, too hot can sometimes be as equally discomforting as too cold IMEX. :smile:

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#5 KTD

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Posted 29 August 2013 - 07:06 PM

Dear AshleySidney -

 

 

     In addition the general FDA fish guidelines that Charles referenced, FDA also came out with guidelines specific to shellfidh (see attached). It was issued a year after the general fish & shellfish guidelines...Hope it helps.

 

The link for the USFDA fisheries guide is http://www.fda.gov/F.../ucm2018426.htm

Attached Files


Edited by KTD, 29 August 2013 - 07:09 PM.


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#6 George @ Safefood 360°

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Posted 29 August 2013 - 11:49 PM

The guys are all correct. Your risk assessment can be simple enough. Identify the hazards, map the actual process over a number of typical packing days e.g. start time, temperature profile over packing, finish times. Where you are looking at temperature increases of chilled or frozen products the external temperature of the product is more important since food thaws from the outside in.

 

Document all this and then do a risk assessment. I am familiar with the process you describe. No significant risks but you need to demonstrate this. Some micro testing might be helpful.

 

George


Edited by George Howlett, 29 August 2013 - 11:50 PM.





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