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Fresh Pastry With Pasteurized Egg = RTC? what micro guidelines?


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DavidAR

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Posted 23 April 2015 - 08:49 AM

Greetings all,

 

i been troweling about 20 pages of this site for micro related shelf life topics and always even through google i find RTE only.

 

In in the process of bedding a new NPD guy in and i need to source a micro guy next but in the mean time i have a problem.

 

EHO came in (UK government guy) and said we need to validate shelf life. he then said all that's needed is to test product at manufacture and again at its USB to verify its ok. Now i understand this and i understand that its actually more involved than this in terms of a standard shelf life process.

 

Currently we store each batch of product produced each day and and organolepticly assess it at the end of its SL and for 6 days later. SL being 10 days.

 

Problem is the micro... im not a microbiologist and our lab service doesn't like making opinions on what we should do, so im stuck.

 

We have a spec for when product is 1st made and an opinion is that its over kill the spec for end of life is a whole other question... based on the spec of at manufacture what should be a trigger point for end of usb?

 

the product Fresh pastry has flour water, colour and pasteurized egg in it. the PH is on average neutral leaning towards acidic(still testing samples.) The aW is 0.91 - 0.97

 

Currently testing for indicators such as ACC, Coli forms  and the testing for Molds, yeasts, E.coli, salmonella, Listeria, bacillus cereus. 

 

my understanding is that molds and yeast being present at manufacture would not be a concern how ever there is the issue of toxins... 

 

it all comes down to are these test sufficient at manufacture? what would the limits be for triggering action.. and once those are set how do you determine if you test at the last day of use if there's a food safety concern? 

 

of a whim i sent a sample out day of manufacture came back clear. at usb there were coliforms at +5000 cf/g and ACC +10000 cfu/g but nothing else all main tests were negative. one sample just had ACC.

 

My gut says we need to investigate what the issue is IE indicated but in terms of shelf life is it safe!! is the product out the door safe?.....

 

(gawd need a micro guy bad!)

 

My thinking is that my base test should be something like indicators + the main obvious programs, + endotoxins, mycotoxins, aflatoxin etc  because of mould growth and the spores / toxins they can produce. 

 

define limits at manufacture (guidelines? RTC?) then calculate what is acceptable not acceptable at end of life / repeat test using same product from start.

 

Any help on this appreciated....... 



Charles.C

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Posted 23 April 2015 - 10:16 AM

Hi DavidAR,

 

Forgive my bakery/cooking ignorance but I struggled to understand what this product is in various ways.

 

the product Fresh pastry has flour water, colour and pasteurized egg in it. the PH is on average neutral leaning towards acidic(still testing samples.) The aW is 0.91 - 0.97

 

It sounds something generically like coloured raw dough with egg in it ?

I deduce it is not classified as RTE and has received no heat treatment at all after mixing ?.

(added - just saw the = RTC so i guess it's classified as raw)

So how is it labelled for the customer’s POV ? (must be fully coooked ?)

How is it stored ? Chilled ? Frozen ? (I (UK) anticipate chill holding at recommended 5degC/max 8degC?)

0.91-0.97 =  FDA/PA  (unless, maybe, pH<4.6 which it probably isn't?). Can you be more specific with pH/aW?

 

Currently we store each batch of product produced each day and and organolepticly assess it at the end of its SL and for 6 days later. SL being 10 days

What was the scientific basis for the 10days ?

 

I imagine the EHO Guy wanted to see a HACCP Plan, Is there one ? if yes, can you share it ?(might save some more questions :smile: )

 

And yes, a tame microbiologist would definitely be a good idea. :smile:

 

There are a few standardized starting points to shelf-life issues but insufficient info. at the moment to even guess AFAIK :smile:


Kind Regards,

 

Charles.C


DavidAR

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Posted 24 April 2015 - 07:20 AM

sorry i do tend to bable,

 

The aW and PH is being investigated right now so we are collecting data as i type.

 

The department which only produces a small amount of product for local customers is not within the scope of our BRC do to low cost and targeted consumers. As a result the my predassor and MD put very little focus in to the HACCP plan and the department as a whole. Here in lays my issue.

 

EHO did indeed want to see our HACCP file but he ran out of time. i looked through it and basically called a meeting to say that it A) needs  ahuge review and B we should stop manufacture untill we resolve the lack of revised accurate plan and shelf life justification.

 

our plan currently uses a generic term microbial growth as a hazard identifier which is very lame and not in my opinion good enough.

 

This being said without knowing the products hazards i have no idea how they ever came up with there shelf life and how they would justify it.

 

Currently i have them taking readings of every batch of product start middle end for aW and PH and i have sent of more regular micro tests to enusre out Date of manufacture is safe to best of my ability knowing that the end user will consume within a few days (historically based on re-orders.)

 

The product is pastry sheets and egg noodle containing, wheat flour gluten colour and egg. all stored between 1-5 degrees with a CCP control of egg being 1-4 at all points.. its sold in sqaure sheets or egg noodle strands which is then delivered to customer in bags for further processing... They store it chilled and either Fry egg noodle or turn the pastry in to stuffing balls where they place some meat stuf inside it and of course then cook...

 

Directions on packaging state essentially: store in chiller 1-5 degrees use within USB if frozen use within 3 days of defrost.

 

or words to that effect..



DavidAR

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Posted 24 April 2015 - 07:21 AM

forgot to mention the pastry is in a vacumn pack so no air present.

the egg noodle is not vac packe.



Charles.C

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Posted 24 April 2015 - 07:54 AM

forgot to mention the pastry is in a vacumn pack so no air present.

the egg noodle is not vac packe.

 

Hi David,

 

Thks for above. The vacuum complicates things a bit.

Is it possible to summarise how you make the sheets without giving away any secrets ?

I'm basically trying to "get" the flowchart/product description steps of the Codex haccp procedure. Definitely no heat applied, yes ?

 

the flow  (yr frozen version) sounds something (+vac.,+egg, -yeast etc) bit like this flowchart ? -

 

Attached File  haccp pastry products.pdf   68.35KB   47 downloads

 

(don't [yet] worry too much about the haccp part in pdf, this doc. is IMO using an atypical HACCP procedure)


Kind Regards,

 

Charles.C


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Posted 24 April 2015 - 10:22 AM

Hi David,

 

After a little searching, i anticipate that the basis of yr current 10 day shelf-life for chilled goods derives fron this link -

 

https://www.food.gov...lf-life-storage

 

This document indicates that you are expected to have validation data for the recommended cooking step to follow -

 

Attached File  chilled food requirements.ppt   4.49MB   58 downloads


Kind Regards,

 

Charles.C


DavidAR

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Posted 24 April 2015 - 03:26 PM

Hi David,

 

Thks for above. The vacuum complicates things a bit.

Is it possible to summarise how you make the sheets without giving away any secrets ?

I'm basically trying to "get" the flowchart/product description steps of the Codex haccp procedure. Definitely no heat applied, yes ?

 

the flow  (yr frozen version) sounds something (+vac.,+egg, -yeast etc) bit like this flowchart ? -

 

attachicon.gifhaccp pastry products.pdf

 

(don't [yet] worry too much about the haccp part in pdf, this doc. is seeing CCPs everywhere in sight)

 

 

Interesting PDF it reads similiar to our HACCP file except for the flow.. the generic term microbial growth is used in this file too with a smal ltable explaining some micro standards...

 

So the there is no heat treatment at any step within our process.

 

egg kept chileld and controleld, only added when required in the main mixer along with flour, water and colour, for pre-determined time.

 

This is then dropepd in to rollers to be formed / needed in to a thin sheet.

 

It is then rolled up and used for either noodle or pastry.

 

as pastry it is transfered to a table where it is cut in to sqaure shapes.

 

it is then weighed and placed in to a bag where it is sealed in a vacum.

 

For noodles from the roll of pastry is then loaded on to a machine that further rolls it out and drops through a blade to cut in to strands of noodle which are weighed and placed in to a non vacume bag.. Both products are sealed up and placed in to chilled storage following metal detection.

 

CCP's are EGG temperature, metal detection, chilled storage.

 

note: we do not use yeast. its a very basic product...



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Posted 24 April 2015 - 05:38 PM

Hi David,

 

Thks for the process information.

 

As I indicated in my earlier post, the haccp analysis in the pdf is IMO "flawed”. I was primarily interested in the flowpath/ingredients.

 

As I understand, yr primary requirement was to review yr haccp plan and validate the shelf life in use.

 

IMO, assuming appropriate PRPs / labeling are implemented, the steps involving  vacuum packing and chilled storage are likely to be sensitive / CCP related  plus possibly others depending on the precise flowchart / time-temperature aspects of the process. However most micro. related (haccp) safety aspects should be eliminated by the consumer’s cooking step although the BCP characteristics should obviously be compliant with yr specification.

C.botulinum/toxin as detailed in link in my previous post is probably a  significant hazard. The available control measures are detailed in the downloads on linked page in my previous post.

 

Similarly, the vacuum stage appears to be critical for the shelf life implemented.

The validation of the shelf life is also discussed in the downloads on the linked page in my previous post.

 

I’m a little puzzled at the recommendations you attributed to the EHO. Perhaps those were related to the haccp documents at hand. Or perhaps there are other local legal requirements which I’m unaware of.

 

Hope the above makes sense. You definitely may need some access to a haccp microbiologist for reviewing the haccp plan.

Please revert if any further queries.

 

PS - Note that a frozen product will have a different haccp micro. interpretation


Kind Regards,

 

Charles.C


DavidAR

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Posted 27 April 2015 - 07:03 AM

Thank you for your help its most appreciated, in all fari hoesty im not entirely sure based on review of our HACCP why the pastry is vac packed but the egg noodle is not. The product is identical in terms of recipe its just the form at which it is packed, one being a sheet the other a noodle.

 

The information provided in the links i have checked out and its very interesting, i had a good look over the FSA site before but i tend to find it hard to navigate and find specific information unless you know exactly what you are looking for.

 

a Microbiologist is something i have requested with my MD for our HACCP team as clearly we need to work on it, so with this in mind i will pass over those links / guides to my collegues so we can all have a read up and push forwrd.

 

 

Question: im right in thinking that our product being fresh and stored chilled is RTC product? but not RTE?

Question: The method for freezing our end product for a specific customer to which i have advised buisiness to stop doing. is only frozen in a normal freezer, its not persay Quick freezing as such. So do you think there could be issues with that? The volumes of production are very small for pastrys and noodles..



Charles.C

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Posted 27 April 2015 - 08:04 AM


(1) Question: im right in thinking that our product being fresh and stored chilled is RTC product? but not RTE?

 

 

(2) Question: The method for freezing our end product for a specific customer to which i have advised buisiness to stop doing. is only frozen in a normal freezer, its not persay Quick freezing as such. So do you think there could be issues with that? The volumes of production are very small for pastrys and noodles..

 

(1) May I ask what it states on the label's cooking instructions ? 

 

(2) I presume by "normal" you mean static, ie zero air flow. The basic answer depends on the temperature / time profile, ie how long it takes to get to "frozen" state. There are some typical requirements which i don't have to hand at the moment.  One common problem is that people overload the freezer so it becomes a crawl.


Kind Regards,

 

Charles.C


Charles.C

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Posted 27 April 2015 - 03:17 PM

Hi David

 

Regarding yr query RTE/RTC, here are defs from Chilled Food Association/UK glossary. I was unable to find any standard def. on FSA site for RTC. The former, and a host of other food acronyms/terminologies  are often interpreted in various ways by different organisations, different food categories and different locations. It's a bit of a mess IMO.

 

Ready-to-cook (RTC) Food: food designed by the producer or manufacturer as requiring cooking or other processing effective to eliminate or reduce to an acceptable level microorganisms of concern before human consumption.

 

Ready-to-eat Food (RTE): food intended by the producer or the manufacturer for direct human consumption without the need for cooking or other processing effective to reduce to an acceptable level or eliminate microorganisms of concern.

 

Ready-to-reheat  (RTRH)  Food:    food  designed  by  the producer  or  manufacturer  as  suitable  for  direct  human consumption without the need for cooking, but which may benefit in organoleptic quality from some warming prior to consumption.

 

 

I assume the flour is categorised as raw (the egg is pasteurized) and since there is no heat applied in yr process, RTE appears not possible. So RTC is the nearest match of the above 3 options IMO. Hopefully the labelling text will agree.

 

Regarding the freezer cooling speed, I could not find any FSA temp./time limits. Elsewhere a varitey of opinions exist. Several of the latter are referenced in this thread –

 

http://www.ifsqn.com...age/#entry47720

 

I have  selected two suggestions as examples – the link fsai.ie and attachment a9 in posts 6, 9 respectively, deriving from Ireland and USDA (see detailed text below).–

 

For the chilling stage of ca. 20degC to 5degC the maximum times suggested in above  range from <2 hours -4 hrs. As far as the further time to reach, say -18degC is involved, so far  found no data.  One reason for the temp. emphasis is that for many common  pathogens (but not L.mono) growth activity slows down considerably below ca.5degC  and stops in, i think, the range ca. (-5) – (-10)degC.

I have extracted/pasted  the texts related to above limits below –

 

(Post 6)(Ireland)

n order to ensure the optimum safety of cook-chill food, chilling should begin within a maximum of 30 minutes following completion of cooking and/or portioning. Following completion of cooking

and/or portioning, all cook-chill food must be chilled to ≤ 3°C within a total time of ≤ 150 minutes (i.e. a maximum of 30 minutes following completion of cooking and/or portioning plus a maximum

of 120 minutes for chilling), followed by chilled storage to ensure a final storage temperature of ≤ 3°C

 

 

(post 9)(USDA)

To assure that potentially hazardous foods are cooled safely through the danger zone, a two-part cooling standard has been developed. They must be cooled from 140°F to 70° F within two hours, and then from 70°F to 41°F within four hours.

Most pathogens optimal growth temperatures fall between 140°F and 70°F, therefore it is crucial to move the temperatures of foods rapidly through this range. Once this temperature range has been passed, pathogen growth slows, and an additional 4 hours can be taken to finish cooling to 41°F. If a potentially hazardous food has been previously held at temperatures in the danger zone, the time they were held at

those temperatures must be accounted for.

You should be aware that this two-part standard may not apply to all foods. The Food Code specifically addresses foods prepared from ingredients held at room temperature, for example, canned chicken. Since the starting temperature of the food is generally around 70°F, they must be cooled to 41°F within four hours. The Food Code also recommends that all ingredients for cold salads be refrigerated prior to assembly.

 

Note -

140F = 60degC

70F = 21.1degC

41F = 5degC

 

One conclusion you will see from the above-linked thread is that most static freezers cannot comply with the above recommendations. (hence air-blast freezers etc)

 

PS - Any other member input only too welcome of course. :smile:


Kind Regards,

 

Charles.C


DavidAR

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Posted 28 April 2015 - 09:19 AM

Again fantastic information, very helpful and i do really appreciate the time it obviously takes to compile it all.

a fascinating read and i totaly agree a standard domestic freezer style process would not ideally meet most recomendations from the above, and like you say blast chillers are used.

 

and for your information our packaging states and i stress, technically the product is not a frozen product. it sold as fresh and a specific local customer asks us to just freeze prior to delivery which is entirely my objection to start with...

 

So assuming fresh egg noodle: ensure noodle ready to use, if frozen ensure it is defrosted by placing in fridge over night, do not re-freeze.

 

Add to boiling water for 30 seconds and remove untill half cooked.

rinse with cold water and drain in a colander

add required ingredients to create a soup

once boiling place noodles in to soup and cook for a further 30 seconds to cook thoroughly.

the noodles are now ready to eat.

 

For the pastry:

Ensure pastry is ready to use, if it was frozen ensure it has defrosted by placing in the refrigerator overnight, if pastry is defrosted do not re-freeze.

take pastry and place a teaspoon of filling in to the centre

moisten the edges of the pastry with water

lift up the 4 corners of the pastry to stick them together to form a parcel.

the pastry is now ready to be boiled or deep fried.

 

Interesting i just noticed they use an acidity regulator in both products. sodium carbonate which i did not mention in the ingredients post above. Sorry. not sure how this affects the microbiology if at all.



Charles.C

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Posted 29 April 2015 - 09:04 AM

Hi David,

 

Thanks for the details. It’s an interesting product(s).

 

Indeed, the Fresh (via) Frozen tag is a globally ubiquitous phenomenon. Yr comment about customer freezing made me wonder how you store it  prior to this final add-on, or perhaps you only produce on demand / “ship” ?

 

The typical micro. threat on eggs, as well known in UK, is Salmonella (Sa). Hence the preference for pasteurized egg (or maybe powder ?).

Sa is similar threat for flour although a nasty event occurred  in USA  due people licking raw cookie dough which was ascribed to E.coli O157 (not generic E.coli) so this should maybe be included in yr routine micro testing.

 

The acidity regulator interacts via pH. This could be particularly relevant in chilled/vac. case as a  further protective hurdle (but will depend on the pH level achieved.) For vac. product, this is discussed within the fsa linked docs previously referenced.

 

AFAIK, any cooking time for finished, nominally, raw product in UK must be minimally cooked for a time based on L.monocytogenes/core food temp. min.70degC/2mins or >= equivalent lethality.

So the noodle cooking instructions for fresh-frozen noodle / fresh-chilled noodle/non.vac would logically have to be validated against the above criterion.

There may be exceptions to the above if the specific packaging/storing method  requires a stricter heat treatment. Vac.pack/chilled  product might be one example (didn’t investigate) but probably not vac.pack/frozen.

From memory, for many products regarded as L.mono “oriented”, it is (UK) sufficient to validate that the product core (or the slowest heated location) reaches an instantaneous temperature of 75 degC, eg –

https://www.croydon....tymgmnt/fd/temp

 

And similarly for the pastry.


Kind Regards,

 

Charles.C





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