Shelf life of meat pies - disagreement with New EHO
Hello everyone.
I have an ex-colleague who now has his own small business making meat pies. He's been up and running for a year or so and everything has been fine up until now.
He has a new EHO who says he is not working out his shelf life properly.
He has always cooked his pie filling in a pan and over the next 48 hours made the pie casings, added the filling and then cooked them to at least 82 degrees C core temperature (never under 90). He has always classed this stage as Day 1 for the shelf life and his EHO has always been happy with this.
However, his new EHO is saying her predecessor is wrong and that pie is now 3 days old. My friend dismisses this as the pie is not made 2 days ago – the filling is cooked up to 2 days ago prior to filling (never more), but then re-heated with the pie casing to at least 82 degrees, so day 1 of the shelf life begins at this point. I agree with him.
Does anyone have any advice on this for taking back to EHO? I've had a look through guidance on the net but cannot pin down anything concrete for him
Kind regards
Poppy
Dear poppysnoss,
The obvious comment is - how is the timing justified by EHO ?
I am intuitively inclined to agree with new EHO (ie the microbiologically conservative viewpoint).
You don’t mention anything about temperature controls / permitted use-by period which I anticipate are practically crucial to the seller in this case. Max. 2 days ? :smile:
The process (esp.48 hrs delay ) seems somewhat odd / precarious (?) from a purely (filling) micro. POV.
I recall re-heating is discussed in the official temperature control segment of UK / RTE food products. But (from memory) with respect to temperature level only.
I also recall certain categories of meat pies are legally special cases in UK regarding extended selling times. (issue emerged at time of the notorious ambient 24hr hamburger case of few years back / featured on this forum). Maybe unrelated here.
Maybe check the official UK “Baked products” book ( ca. 1990 but I believe still operational). Posted on this forum somewhere / available online.
Rgds / Charles.C
PS (afterthought) - I also recall there is a model UK HACCP control document for meat pies issued as an example of an EHO inspection existing ( I posted it on this forum somewhere )
Hi Charles,
Thank you for the reply. I'm afraid I have limited information in this case. :-( I know that he has always counted day 1 from the time the pie was put together and had undergone it's heat treatment - and his previous EHO was happy with this. However, the new EHO says he cannot do this and he must class day 1 as when he originally cooks the meat.
I do understand where she is coming from, but you surely can't class a substantial heat treatment as day 2 or 3? Or can you...? If she is correct, he will need to change his HACCP, labelling etc. However, i am not as yet convinced she is correct.
I agree with Charles. First thing to do is confirm whether or not there is a legislated requirement specific for determining shelf life of pies. I expect that there is not a requirement stated, as you guys probably would have known about it, given that is your specific industry expertise.
If there is no specific requirement, then it seems to me that the EHO would be correct to commence the shelf life calculation from the time the filling was first cooked. Re-setting shelf lives by re-cooking is a practice in a commercial setting that can be 'abused'. If it was allowed, then operators could cook fillings and refrigerate, well in advance, then re-cook any unused filling to extend shelf life; a behaviour that is bound to go wrong eventually and should be discouraged.
Easy fix. Make the casings first! :)
Just my thoughts.....
I agree with Charles. First thing to do is confirm whether or not there is a legislated requirement specific for determining shelf life of pies. I expect that there is not a requirement stated, as you guys probably would have known about it, given that is your specific industry expertise.
If there is no specific requirement, then it seems to me that the EHO would be correct to commence the shelf life calculation from the time the filling was first cooked. Re-setting shelf lives by re-cooking is a practice in a commercial setting that can be 'abused'. If it was allowed, then operators could cook fillings and refrigerate, well in advance, then re-cook any unused filling to extend shelf life; a behaviour that is bound to go wrong eventually and should be discouraged.
Easy fix. Make the casings first! :)
Just my thoughts.....
This suggested easy fix is so obvious, I can't quite see why your friend is courting problems by not applying it in the first place?!! Does he leave the cooked meat for 2 days to mature taste-wise perhaps?
The shelf life of meat depends on the meat type. Usually one week of shelf life is there, however you can never be sure about it.
The shelf life of meat depends on the meat type. Usually one week of shelf life is there, however you can never be sure about it.
Temperature ?
Rgds / Charles.C
Firstly, has the shelf life of the pie filling been established, and from what point.
If he can demonstrate that the pie filling has a shelf life of X days from the second cook, then he could say that the pie filling is an ingredient. But he needs to have the relevant evidence to show this. He would also need to demonstrate that there is no longer than 48 hours (as stated in your post) been first cook & second cook.
He contradicts himself in saying that he cooks pie filling "at least 82 degrees C core temperature (never under 90)".?? What is the CCP temperature here and what is the holding time? (validation). Also are the pies sold cooked or ready to bake? Is the pie a hot or cold fill? There are a number of things that he needs to address as part of the HACCP / evidence for shelf life.
We make a product that we give 20 days shelf life to. However, one of the ingredients can come in with <20 days. We then alter the shelf life to that of the lowest date on ingredient to compensate for this ingredient not have sufficient life.
Caz
What is the total shelf life?
If he's baking to >82 core temperature, then the EHO, if they're sufficiently knowledgable, is concerned about Clostridium Botulinum I would guess? In which case, if it is a large batch of filling so mostly anaerobic and a pie interior is likely to be anaerobic, then the total life from the initial pie filling being made should be no more than 10 days unless he has established a hurdle factor which would inhibit growth or paid £5k for Campden to challenge test it.
So I'm down with the EHO on this unless his shelf life is short.
(Obviously assuming the filling and pie are kept chilled.)