11 replies to this topic

[BarrieT]

Good Morning (it is here, anyway!)

 

Does anyone have good information on the safety aspects of extending the Use By date beyond the recommended (in UK) 10 days for vacuum packing hard cheese and bacon?

 

I don't particularly want to go down the route of sending cheese/bacon off to the Lab, as the amount we sell doesn't really warrant the cost, but our local EHO is insisting that we do not go over the 10 days, even though the bulk cheese arrives with a 3 week+ date on it.

 

I was rather hoping someone could suggest good documented 'evidence' to support a longer shelf life due to pH, salt content, water activity, etc.  I've scoured Google ad nauseum but haven't been able to find what I need.

 

Any help would be greatly appreciated.

 

Barrie

[Quality Ben]

Hi Barrie,

 

Are you talking about separate products or is the product 'VPd cheese and bacon' ?

 

Regards,

[Slab]

Hi, Barrie;

 

I'm not all that familiar with UK regulations, but in the US in such instances a variance is allowed when (as illustrated in table 2 of first attachment) a product is deemed low risk because of inherent properties.  However the burden is on you to prove acceptable variance criteria through proper risk assessment.  

 

 

 FSA vacpacguide 2008.pdf   237.05KB   58 downloads

 

 ACMS far2006.pdf   141.17KB   52 downloads

 

Here is pretty cool website for EHO's 

 

http://vacuumpacking...tion1/?panel=18

 

[edit]

 

I should mention that I read an FDA article(?) about guidance for shelf life.  The key findings of the article addressed the main concerns for food safety on the cold storage methods and practices of retail establishments, and not the manufacturer.  However it concluded (memory is a little fuzzy here), that it would be simpler to control the manufacturer's dating, than it would be to control point of sale.  Perhaps this is the reasoning as well with the FSA?

Edited by Slab, 20 June 2014 - 11:59 AM.

[BarrieT]

Hi Barrie,

 

Are you talking about separate products or is the product 'VPd cheese and bacon' ?

 

Regards,

They are separate products.

[cazyncymru]

Barrie, I think you really are going to have to bite the bullet and do a shelf life evaluation.

 

Correct me if I'm wrong, but this is how I see your business working

 

You buy in cheese / bacon which has a shelf life of 21days + shelf life on it, which we'll call day 1

 

You pack the product on day in MAP on day 2, and give it 10 days, a shelf life which you already have data to substantiate.

 

Question I have is, did the original product come into you in MAP?

 

If you want to extend the shelf life (assuming you have 10 days left from the original date of 21 days) you will need to test each day until results become unacceptable. Your need to repeat to ensure the data you have is meaningful.

 

Lets say that results on 3 trials were all good until day 18, you can then look at saying that shelf life is good to day 15 or 16, and have data to back it up.

Obviously, if the raw material has a shelf life of less that the packed product shelf life, then you need to take this into consideration.

 

If you can't demonstrate this, your EHO may just prosecute you.

 

Caz

[BarrieT]

Hi, Barrie;

 

I'm not all that familiar with UK regulations, but in the US in such instances a variance is allowed when (as illustrated in table 2 of first attachment) a product is deemed low risk because of inherent properties.  However the burden is on you to prove acceptable variance criteria through proper risk assessment.  

 

 

FSA vacpacguide 2008.pdf

 

ACMS far2006.pdf

 

Here is pretty cool website for EHO's 

 

http://vacuumpacking...tion1/?panel=18

 

[edit]

 

I should mention that I read an FDA article(?) about guidance for shelf life.  The key findings of the article addressed the main concerns for food safety on the cold storage methods and practices of retail establishments, and not the manufacturer.  However it concluded (memory is a little fuzzy here), that it would be simpler to control the manufacturer's dating, than it would be to control point of sale.  Perhaps this is the reasoning as well with the FSA?

 

Many thanks for the references, Slab.  I already have these documents, but they don't really provide me with enough hard evidence to support (hopefully) my  risk assessment decision to extend the shelf life of the products.

 

I think I may need to bite the bullet and get some cheese and bacon analysed for salt / pH / A_w, etc....!

[BarrieT]

Barrie, I think you really are going to have to bite the bullet and do a shelf life evaluation.

 

Correct me if I'm wrong, but this is how I see your business working

 

You buy in cheese / bacon which has a shelf life of 21days + shelf life on it, which we'll call day 1

 

You pack the product on day in MAP on day 2, and give it 10 days, a shelf life which you already have data to substantiate.

 

Question I have is, did the original product come into you in MAP?

 

If you want to extend the shelf life (assuming you have 10 days left from the original date of 21 days) you will need to test each day until results become unacceptable. Your need to repeat to ensure the data you have is meaningful.

 

Lets say that results on 3 trials were all good until day 18, you can then look at saying that shelf life is good to day 15 or 16, and have data to back it up.

Obviously, if the raw material has a shelf life of less that the packed product shelf life, then you need to take this into consideration.

 

If you can't demonstrate this, your EHO may just prosecute you.

 

Caz

 

Thanks Caz - your reply crossed over with my response to Slab, so you'll see I'm already starting to resign myself to spending some (of the boss's) money at the Lab......!

 

I guess we could just cling-film the cheese (it's for retail sale) and we wouldn't need to worry so much about this 10 day rule - but then I'd probably need to do even more expensive analysis to check no migration of chemicals......

 

.....aren't we lucky to be living in countries which agonise over these 'food safety' issues, rather than one where they have no food at all, let alone worry about its safety!??!!

[Charles.C]

Dear Barrrie,

 

I presume the bulk cheese is not vacuum packed, ie the 3 weeks+  is unrelated to yr actual question.

 

As per the attachment in previous post, you are clearly required to provide some further specific data to support yr case for an extended time of storage.

 

I am rather surprised that the EHO seems to not have mentioned this. Only aware of advised limit of 10 days ?

 

Does everyone in UK use 10 days in practice for this product(s) ?  How about in the supermarket ? (I predict >10days exists)

 

Rgds / Charles.C

 

PS - post overlapped previous but I am now surprised you haven't got the data yet.   Hoping for a miracle revelation ?

[BarrieT]

Yes Charles! I was rather hoping someone would post that they've come across the problem before and could quote a lovely bit of research which would rubbish the idea that cheddar cheese would become a deadly soup of botulinum toxin just 10 days after being vac-packed......!!

 

Dream on........

[Slab]

Many thanks for the references, Slab.  I already have these documents, but they don't really provide me with enough hard evidence to support (hopefully) my  risk assessment decision to extend the shelf life of the products.

 

I think I may need to bite the bullet and get some cheese and bacon analysed for salt / pH / A_w, etc....!

 

I was sure you had already reviewed the attached references. My MO is only to provide reference for the topic, not necessarily for the OP. 

 

Yes Charles! I was rather hoping someone would post that they've come across the problem before and could quote a lovely bit of research which would rubbish the idea that cheddar cheese would become a deadly soup of botulinum toxin just 10 days after being vac-packed......!!

 

Dream on........

 

C. bot A B E is relatively easy to control for hard cheeses. Typically .97 a_w  is sufficient  to control non-proteolytic and anaerobic pathogens (I think LM may be the exception?). ROP is a great way of preserving such food items against aerobic spoilage bacteria, and hence increase shelf life.  I'm still confused as to the reasoning as I just purchased an 8 oz block of sharp cheddar that expires in October!

 

If you are only repacking cheese then have the supplier provide you with a COA and eliminate the lab cost (unless your process hazard analysis deems otherwise)?   

Edited by Slab, 20 June 2014 - 04:37 PM.

[Charles.C]

Dear Barrie,

 

These few extracts may assist yr cheese dream, somewhat –

2.13 Dairy products

MAP is used widely in hard cheese packaging. For example, cheddar has a 3 month shelf

life, 1.75% NaCl, pH control through maturation, resulting in C. botulinum control

 

 

And a doublet from USA –

3.4.3 The position in the USA

The 2005 Food Code also allows reduced oxygen packaging for hard cheeses, semi-soft

cheeses, and pasteurised processed cheeses, but limits shelf life to 30 days. ROP of unfrozen

fish is not permitted.

(USA)

 

3.4.3.2 Cheese 

The 2005 Food Code allows a food establishment may package cheese using a reduced oxygen

packaging method without obtaining a variance if 

•    the cheese is commercially manufactured within a HACCP plan, and

•    has no other ingredients added, and 

•    meets the Standards of Identity for hard cheeses, pasteurized processed cheese or semisoft

cheeses, and

•    it labels the package with a “use by” date that does not exceed 30 days or the original

manufacturer’s “sell by” or “use by” date, whichever occurs first; and

•    discards the reduced oxygen packaged cheese if it is not sold for off-premises consumption

or consumed within 30 calendar days of its packaging

 

 C.botulinum,vacuum packed, MAP,chilled foods.IFR,2006.pdf   1.22MB   30 downloads

(I daresay  this was the “heavy-lifting” basis of the FSA 2008’s previous attached document)

 

Also see these quite interesting links –

 

http://www.dairyscie...e_topic332.html

(UK situation, 2012)

 

http://cheeseforum.o...hp?topic=6794.0

(esp. [probably]USA origin posts 6,9)

 

Rgds / Charles.C

 

PS- bacon looks more complicated, eg (USA)  -

 

1. (H) Foods Which Require a Variance Under Code Section 3-502.11 if Packaged in Reduced Oxygen Atmosphere

   1. (1) Unfrozen processed fish and smoked fish may not be packed by ROP unless retail food establishments have an approved variance application and HACCP plan to show C. botulinum spore germination and toxin production or L. monocytogenes growth will not occur and are inspected by the regulatory authority. Establishments packaging such fish products, and smoking and packing establishments, must be licensed in accordance with applicable law.
   2. (2) Soft cheeses such as ricotta, cottage cheese, cheese spreads, and combinations of cheese with other ingredients such as vegetables, meat, or fish at retail must be approved for ROP through an approved variance application and HACCP plan and be inspected by the regulatory authority.
   3. (3) Meat or poultry products which are smoked or cured at retail, except that raw food of animal origin which is cured in a USDA-regulated processing plant, or establishment approved by the regulatory authority to cure these foods, may be smoked in accordance with approved time/temperature requirements and packaged in ROP at retail if approved by the regulatory authority. Smoking which meets the time/temperature parameters in Section 3-401.11 does not require a variance. Cold smoking where the temperature achieved by the product is greater than 41°F requires a variance. Curing using nitrite or nitrate always requires a variance
   http://www.fda.gov/F...e/ucm188201.htm

[BarrieT]

Charles, sorry for the delay in thanking you for this information - I've been away working with access to the internet restricted to my smart phone, and it's not easy to see the small print on its screen!

 

The information/links have been really useful and I very much appreciate the time you (and others) have taken to help me wade through this issue.

 

Thanks everyone!

 

Barrie