Inspector suggests cooling of pre cooked filling is a CCP

As a stage of the production of meat pies the filling is prepared and cooked a day in advance, then cooled and stored under refrigeration. Preformed and chilled uncooked pastry cases are then filled with the cooked filling before being cooked again achieving a core temperature of over 90 degrees for the filling. These elements of processing are described and controlled within the prerequisite programmes.

The pies are then sold as a freshly cooked product.

An inspector has suggested that the cooling of the meat filling must be identified as a CCP within the HACCP.

It would be valuable to hear the views of colleagues.

Rob Marriner,

 

Your inspector is correct, cooling should be a CCP.  The purpose being, to assure that the meat product cools down to the temperature required in the time required by the regulations.  I would add that having the cooking process as a CCP would also be smart.

 

For the USDA, the cooking CCP would require the product to reach 165 degrees F or above for a specific amount of time (ex: 30 seconds-1 min).  The cooling CCP would consist of 2 temperature readings.  1) 165 F+ to 80 F in 2 hours (approximate), and 2) 80 F to 40 F in 5 hours (approximate).  With these 2 CCPs, the entire process from batching to cooler/freezer is covered.

 

Check your local regulations to see what the time and temperature requirements are.

Hi Rob,

 

One of the typical suspects -

 

https://en.wikipedia...ium_perfringens

I agree. Some years ago I was QM for a cook-chill company making soups, sauces and rice pudding. After filling, we put the product in our blast chiller with CCPs of 2hrs to can't remember and 4hrs to below 5 Deg C. After that the product was moved to the chilled store for distribution. We were SALSA, not BRC.