34 replies to this topic

[RRF]

I need a little guidance if someone has some 1st hand knowledge on a RTE (Ready To Eat) HACCP Plan. We generally process items that we internally cook therefore we process them until they reach a kill step. We are going to start processing a meat product that will be fully cooked when we receive it, we will only be slicing the product therefore no kill step. I understand that my only options to control pathogen growth is with time and temperature as well as sanitation. My question is, do anyone of you have similar current HACCP plans? Is Cold Storage a CCP? If so, what is the critical limit? What scientific data did you use to support you decision?

[Marshenko]

Assuming:  you already have systems in place to monitor temperatures at receiving, and that you regularly monitor cooler temperatures, my feeling is that your CCP would be temperature of product at handling (i.e. slicing), which is the step most likely to bring the product up to an unsafe temperature.  Temperatures at receiving and during storage will be control points, but not CCPs.

 

Then, go ahead and snag the article linked below and set your CCP to 41F.  IMHO.

 

 

http://www.foodsafet...ne-reevaluated/

Edited by Marshenko, 26 February 2014 - 07:27 PM.

[genebartholomew]

Quite simply, RTE or fully cooked items are free of pathogens, except for spore formers such as Clostridium perfringens and botulinum. Neither grow particualrly well below 55F. So you do not need a CCP for managing temperature, period. Temperature abuse will lead to spoiled product but not high levels of pathogens. My company has many plans like this and never had a problem. What you may want to include as a CCP is the transition from shipping anad sotrage in your facility to getting logs into your slicing room. How are you going to do that without potentially contaminating the surface of the log/product? Remember, the back of a truck is not sanitary and free of Listeria. SO here is an opportunity to control introduction of a pathogen by the transit process. This is where you need to focus your attention.

[Charles.C]

Dear genebartholomew,

 

With all due respect, IMO yr post is rather simplified/debatable with respect to FS concepts and the OP. It may well be that yr own experience is endowed with a superbly controlled environment / process but ..........

 

Unfortunately no mention is made in the OP of product/processing area temperatures or the times involved. I recall another thread here where all the handling/processing was carried out within an environment controlled at maximum 5degC. This would I believe be illegal in UK, a tribute to the home of lumberjacks perhaps ?

 

free of pathogens

This is technical slang but even so i suspect is not necessarily true for all vegetative species as per my understanding of US cooking philosophy based on 6-7D for Salmonella ?

 

You seem to have totally disregarded the possibilities of cross-contamination during processing.? If not the case then I suggest that - 

 

Temperature abuse will lead to spoiled product but not high levels of pathogens

is potentially rather optimistic. And even more so if already occurred prior to manipulations.

 

I suspect that the minimum CCPs will actually be highly dictated by USDA ? bit surprised that no-one has provided a link yet ?

 

This OP looks "closely associated" ( ) with  -

 

http://www.ifsqn.com...eat/#entry68731

 

Rgds / Charles.C

 

PS - regarding Cold storage as a CCP, I presume you mean -18degC maximum temperature requirement. It is true that some haccp plans do include this as a CCP but I can only believe that this was due to a known/unavoidable case of their possessing highly suspect freezing machinery and including it as a protective fall-back. i suggest you ask yourself how many times yr product has experienced a (temporary) situation where the product has approached a temperature which can be regarded as a low risk but potential critical limit (from memory officially ca. -12degC in EC)?. Of course, if the answer is frequently, then you may have a genuine CCP also.

 

You might equivalently pose the same question for the time to reach storage temperature. This has also occupied several previous threads on this forum.

 

I also daresay Cold Storage is a USDA Prerequisite thereby removing the necessity for detailed discussion ?

 

PPS - I really, really hope that we are not talking about chilled finished product.

[Jewl578]

RRF,

 

We process RTE USDA products.

Our CCP's are:

 

Cook - 160°F meat - 165°F poultry. We use fully cooked meat or poultry.

Chill/Freeze  - out of freeze tunnel must be 40°F or less (typically we are at 20°F or less, depending on product)

Metal Detect

 

Product is stored at 0 to -10°F. Freezer temperatures are monitored and recorded twice a day. Not a CCP.

 

[Charles.C]

RRF,

 

We process RTE USDA products.

Our CCP's are:

 

Cook - 160°F meat - 165°F poultry. We use fully cooked meat or poultry.

Chill/Freeze  - out of freeze tunnel must be 40°F or less (typically we are at 20°F or less, depending on product)

Metal Detect

 

Product is stored at 0 to -10°F. Freezer temperatures are monitored and recorded twice a day. Not a CCP.

 

Dear jbickle,

 

yr data is a little confusing, eg 40degF = chilled, 20degF = frozen ??

I deduce yr stored product (in a "freezer") is intended to have approx temperatures of -18degC to -23degC. This should be (hard) frozen I presume.

 

thks for yr input but can you perhaps also consider last part of OP -

 

What scientific data did you use to support you® decision?

 

Offhand, i never use "freezing equipment" output temperatures as CCPs but perhaps the USDA do for some reason ?

 

Rgds / Charles.C

[RRF]

RRF,

 

We process RTE USDA products.

Our CCP's are:

 

Cook - 160°F meat - 165°F poultry. We use fully cooked meat or poultry.

Chill/Freeze  - out of freeze tunnel must be 40°F or less (typically we are at 20°F or less, depending on product)

Metal Detect

 

Product is stored at 0 to -10°F. Freezer temperatures are monitored and recorded twice a day. Not a CCP.

jbickle -

 

This is similar to our HACCP Plan for our Fully Cooked - Not Shelf Stable product that we cook in house.

 

However, my question lies in RTE that is NOT COOKED on site. Product that is received in already cooked and we are only further processing it by slicing it for a customer. 

[Charles.C]

Dear RRF,

 

So what are yr environment/product temperatures like ? And for how long, eg 10minutes, 2hours ??

 

And is finished product  chilled or frozen ?

 

Rgds / Charles.C

 

PS - I still anticipate that the USDA have specific expectations for yr process. i deduce you do not have one of their inspectors permanently located on yr premises as in some posts here ?.

[RRF]

Dear RRF,

 

So what are yr environment/product temperatures like ? And for how long, eg 10minutes, 2hours ??

 

And is finished product  chilled or frozen ?

 

Rgds / Charles.C

 

PS - I still anticipate that the USDA have specific expectations for yr process. i deduce you do not have one of their inspectors permanently located on yr premises as in some posts here ?.

Charles -

 

We will be slicing in a non-refrigerated room. Thought process is to take product temp every 30 mins during processing to insure the product temp does not exceed 41. We will always insure inbound product is received under 41.

 

We are a USDA inspected facility and do have an inspector on site. However, most inspectors will not provide guidance on building HACCP plans. 

 

Product will be frozen after slicing.

[Charles.C]

Dear RRF,

 

Thanks for input.

 

We are a USDA inspected facility and do have an inspector on site. However, most inspectors will not provide guidance on building HACCP plans

 

 

Strange. In other threads here the inspector seemed to do nothing but criticise/discuss the implementation of CCPs.

 

Regardless the USDA do, I believe, offer substantial published recommendations for a variety of processes /  CCPs ?

 

As far as Frozen Cold Storage per se is concerned (yr OP), the previous steps are IMO somewhat irrelevant unless the room is also being used as a freezer (old traditional method) or the temperature output from yr freezing equipment (?) is inadequate (should typically be under relatively low stress if input at around 41degF or less and not overloaded).

 

The important time parameter is the residence time prior to freezing for a given unit at temperatures where significant microbial growth can occur. Meat not my area but the allowable times for "non-concern" for seafood assuming the temperatures are controlled as you indicate would be substantial and typically IMO not constitute a significant hazard (frankly I'm surprised you can maintain the temperature you mention without a cooled room unless transit time is very rapid or ambient is low). However i would not be amazed if regulatory standards existed for such stages in USA (including the room temperature itself).

 

Rgds / Charles.C

 

(added) - PS - as far as scientific validation is concerned, i recall a related thread here for the freezing equipment of meat (?) products where the poster in UK wished to set a CCP. I posted the reasons why this was unnecessary by reference to (US) CFR haccp requirements where, from memory, it was categorised as a prerequisite. Don't remember if CFR also included the storage location also. Perhaps USDA would consider CFR to be a valid general reference ?

[Marshenko]

Charles,

All due respect, you're making this entirely too difficult. 

 

He's bringing cooked meat in, storing it, then slicing it for a RTE product.  He may have misspoke in using the exact phrase "cold storage" when all he really means is throwing it in a monitored cooler or freezer prior to processing.

 

OP - Be sure to include this new process/product in your listeria monitoring program.

 

PS - USDA inspectors can't help with development of plans, they can only criticize after the fact

PPS - USDA published recommendations are oftentimes terrible, but at least do provide a starting point from which any good meat HACCP plan should vary significantly

[Charles.C]

Dear Marshenko,

 

You are probably correct. i certainly hope that USDA will agree.

A little knowledge is a dangerous thing.

 

So the consensus for USDA / OP is No CCP for Frozen Cold Storage.

 

Regarding yr PPS, i would imagine that RRF might be interested in a link to yr USDA knowledge if relevant to his process ?

 

Rgds / Charles.C.

[Marshenko]

No CCP for receiving or storage IMO.  My one CCP would be at slicing, though I am not sure I'd be monitoring it quite as frequently (though I suppose it depends on how many personnel you have and the speed of your line).

 

I've pretty much written this exact HACCP plan a couple of times and it is received just fine by the USDA, even during an FSA.  As long as he is actually monitoring temps at receiving and has some sort of cooler monitoring program, will be A-OK.

 

FSIS model HACCP plans:  http://www.fsis.usda...plans-guidebook

 

FSIS Microbiological Hazard Identification Guide:  http://www.fsis.usda...cp/hidguide.htm

[Charles.C]

Dear Marshenko,

 

Thks for the links.

 

I guess that the last part of Plan 12 is the closest approximation to the current process under discussion ?.

 

It appears that USDA do regard Frozen Cold Storage as a CCP for the "scientific" reasons stated therein.

 

Rgds / Charles.C

[Marshenko]

The USDA makes a lot of ridiculous suggestions

Edited by Marshenko, 27 February 2014 - 06:35 PM.

[Slab]

It's very interesting to see the differences between USDA and FDA HACCP hazards guidance. 

 

I do have a question for RRF;

 

How is the product received, and what type of packaging?

[Charles.C]

The USDA makes a lot of ridiculous suggestions

Dear Marshenko,

 

Do you mean they are not regulatory suggestions ?

 

Rgds / Charles.C

[RRF]

It's very interesting to see the differences between USDA and FDA HACCP hazards guidance. 

 

I do have a question for RRF;

 

How is the product received, and what type of packaging?

Slab -

 

Product is received frozen, is cases. Individual brisket pieces are packaged in a shrink package.

 

We would be thawing under refrigeration. Slicing and packaging sliced product into a bag lined case loose packed.

[RRF]

Dear Marshenko,

 

Thks for the links.

 

I guess that the last part of Plan 12 is the closest approximation to the current process under discussion ?.

 

It appears that USDA do regard Frozen Cold Storage as a CCP for the "scientific" reasons stated therein.

 

Rgds / Charles.C

Charles -

 

Plan 12 refers to "cooking" a product that will then be labeled a Fully Cooked Ready-to-Eat product that is not shelf stable. They don't have a reference for just further processing a product that you purchase already cooked.

[Slab]

Slab -

 

Product is received frozen, is cases. Individual brisket pieces are packaged in a shrink package.

 

We would be thawing under refrigeration. Slicing and packaging sliced product into a bag lined case loose packed.

 

 

I suspected so.  Under FDA guidance thawing operations under cold storage with anaerobic packaging becomes a CCP.  If indeed the packaging is anaerobic (normally frozen product is non-10k IVP) my concerns are elevated more so because it's RTE and potential for c. botulinum growth.  

If you have access to 24 hour temp data log on demand then you have an easy fix to a CCP.

Just my thoughts, but it seems I'm a bit ignorant on USDA logic! 

[Marshenko]

Here... reference the "meat and cheese platter" as it pretty closely resembles what you are trying to achieve:

 

http://www.meathaccp...elf_stable.html

 

The only difference is instead of "assembly" you'll be "slicing" before packaging really.

[RRF]

I suspected so.  Under FDA guidance thawing operations under cold storage with anaerobic packaging becomes a CCP.  If indeed the packaging is anaerobic (normally frozen product is non-10k IVP) my concerns are elevated more so because it's RTE and potential for c. botulinum growth.  

If you have access to 24 hour temp data log on demand then you have an easy fix to a CCP.

Just my thoughts, but it seems I'm a bit ignorant on USDA logic! 

We will be using a Sensitech TempTale 4 to monitor the ambient room temperature 24 hours a day (we can determine the increments of the readings). The room is also equipped with an alarm that will sound/call someone if the temperature exceeds its alarm point. 

[Marshenko]

I suspected so.  Under FDA guidance thawing operations under cold storage with anaerobic packaging becomes a CCP.  If indeed the packaging is anaerobic (normally frozen product is non-10k IVP) my concerns are elevated more so because it's RTE and potential for c. botulinum growth.  

If you have access to 24 hour temp data log on demand then you have an easy fix to a CCP.

Just my thoughts, but it seems I'm a bit ignorant on USDA logic! 

 

C.botulinum in meat products other than sausage/salame products in casings?  There's a reason the FDA addresses these at length but the USDA does not.

[RRF]

Here... reference the "meat and cheese platter" as it pretty closely resembles what you are trying to achieve:

 

http://www.meathaccp...elf_stable.html

 

The only difference is instead of "assembly" you'll be "slicing" before packaging really.

yes, I had actually just come across this one as well. They are only listing 1 CCP during processing, which was my initial thoughts as well but I am still debating on whether the storage would be a CCP or if we can have a monitoring step that keeps it from being a CCP.

[Charles.C]

Charles -

 

Plan 12 refers to "cooking" a product that will then be labeled a Fully Cooked Ready-to-Eat product that is not shelf stable. They don't have a reference for just further processing a product that you purchase already cooked.

 

Dear RRF,

 

The point is that the (1999) document apparently expresses the current (generic) USDA haccp viewpoint on the risk of Frozen Cold Storage.

The previous posts suggest their actual viewpoint is flexible. I guess you will have to determine how much flexible.

 

Rgds / Charles.C