9 replies to this topic

[speedysnacks]

Would veal trim destined for a raw ground grinding operation that produces raw ground veal and raw ground veal patties that will be sold to consumers  as raw ground veal or patties be considered low, medium or high risk raw material?

[SQFconsultant]

HR

[Charles.C]

Dear speedysnacks,

 

Define yr "high risk". i thought the USA had long ago stopped using this terminology ?.

 

Rgds / Charles.C

[speedysnacks]

Thanks Charles,

My question is based on the SQF definition of High Risk Products. The definition that currently appears in The SQF Code Edition 7 is as follows:

 

High Risk Food

A food that may contain pathogenic microorganisms and will support formation of toxins or

growth of pathogenic microorganisms, and has a significant likelihood of growth causing

illness or injury to a consumer if not properly produced, processed, distributed and/or

prepared for consumption. It may also apply to a food that is deemed high risk by a

customer, declared high risk by the relevant food regulation or has caused a major

foodborne illness outbreak.

 

With that said, how would you define veal trim as outlined in my question? 

[cazyncymru]

High Risk. I'm sure raw veal, trim or not, would support pathogens!

[Charles.C]

Dear speedysnacks,

 

Well spotted ! Must confess i hadn't noticed the post was in the scary SQF forum.

 

I noticed the SQF definition of Low Risk  Food  - "A food that is not classified as high risk". 

It appears there is no SQF medium risk. Fair enough although rather un-HACCP like perhaps.

 

i also noticed this amazingly scientific item in the SQF def. - "It may also apply to a food that is deemed high risk by a customer".   

 

More seriously, do note this other caveat -  "and has a significant likelihood of growth causing illness or injury to a consumer if not properly produced, processed, distributed and/or prepared for consumption".

 

So, assuming that, despite perfect production control, there is micro. pathogenic contamination such as E.coli O157 present at the point of sale,  what is yr assessment of the likelihood of your customers being incapable of properly cooking  your veal ? (I assume we are talking about a hazard from relevant pathogens rather than, say, metal).

 

I guess you are interested in SQF category no.8 ?.

 

If so, It appears that SQF do in fact consider that the average consumer's cooking capability is significantly "unsafe", as evidenced by the right-hand table entry on pg 178 of the Code. I deduce this reflects a  still-prevailing fear resulting from the historical local preference for eating  undercooked meat / pathogenic E.coli. 

 

pg178 appears to imply that any processed product from meat or poultry, other than canned, is classified as high risk. How about USFDA's risk assessment ? 

 

It would be interesting to compare this conclusion to the situation in other locations. 

 

Rgds / Charles.C

 

PS i hope my category interpretation was correct. If No.7, the result is apparently, and perhaps curiously, low risk.

[Charles.C]

Dear speedysnacks,

 

Any more thought on which SQF category is involved in yr query ? I incline to No.7 Just curious.

 

Out of interest, i have done a little more searching - here is BRC's food viewpoint,  (I guess a sort of unofficial UK "standard") -

 

High-risk product - A chilled ready-to-eat/heat** product or food where there is a high risk of growth of pathogenic micro-organisms

( **Reheat – products that are designed to be safe to be consumed without the need for a full cook; the reheating of the product is intended to make the product more palatable and is not a microbiological kill step. )

.

BRC only have a High-Risk product, no Low or Medium

 

I guess yr query would be non-High Risk on above basis although, strictly, i think the BRC definition is more concerned with finished products.

 

Regarding USDA / FSIS, the nearest info. on yr query I could find was a 2002 Guidance document for Beef Grinding Operations (attached below) stating -

 

Separate processing of meat into lower risk and higher risk categories. Lower risk materials are those that pass the microbial purchase specifications, or those that came from suppliers that have effective antimicrobial intervention methods, or those materials where E. coli O157:H7 or Salmonella were not detected.

.(Pg 14)

 FSIS Guidance for Beef Grinders.pdf   203.31KB   56 downloads

 

Above document is stated to have been updated in 2012 but seems to not exist on USDA / FSIS websites. Curious.

 

Rgds / Charles.C

[speedysnacks]

The food sector category is 8. 

[Tony-C]

Dear speedysnacks,

.

BRC only have a High-Risk product, no Low or Medium

 

Rgds / Charles.C

 

 

BRC catgorises by production zone and has a production zone decision tree on page 97 of the standard and page 112 of the guidance, in this case raw meat which will undergo full cooking is categorised as a low risk area.
BRC requires 'The food safety controls operated within the factory areas shall be appropriate for the risks of the product'.
BRC also provides guidelines on defining production zones starting on page 94 of the standard and lists examples of the types of product in each category. Risk zones categories are:
Enclosed product area
Low risk - open product area
High care - open product area
High risk - open product area


SQF describes level of risk in SQF Code Appendix 1: SQF Food Sector Categories - 8 Processing of Manufactured Meats and Poultry (Page 178) is described as High risk product and process knowledge required.

 

Regards,

 

Tony

[Charles.C]

Hi Tony,

 

As you say, there is no doubting that the “area” concept is currently fashionable in the food, risk classification genre, at least in EC.  A stolen concept from the chilled, RTE foods department perhaps.

 

BRC6, in addition to Glossary, does contain this note within their segment on high risk areas –

 

Products considered as high risk include cooked sliced meats, fully cooked prepared meals and dairy desserts

.

 

Together with the Glossary text, I get the impression that BRC are implying that products from both  high risk / high care “areas” are, for BRC, assumed to be high risk “products”.  However, from experience of BRC, I may be completely wrong.

 

Frankly, I suspect that SQF would like to  consider all PHFs as High Risk. A rather innovative approach perhaps.

 

The SQF, HR product definition  IMO looks to be based on a truncated definition of PHF + a  miscellany of  other factors, some relevant, some debatable and some irrelevant.

 

As I understand from the SQF text on pg178, meat trim produced by a retail butcher will be Low Risk  (code7) but if it comes from a, presumably, full process capable,  Meat “Processor” will be High Risk (code8).

I fail to see the distinction between the 2 routes  within the context of the SQF definition of HR product. (if anything I would hv thought the reverse classification might be more logical, with apologies to all butcher shops. )

 

Perhaps I am misinterpreting the (intended) implications of  page 178.

 

Rgds / Charles.C