Hi Charles, Thanks for the feedback and the document it sure has been helpful!
We are aiming towards a HACCP certification to begin with then scale up to a FSSC 22000, it's easier this way right?
Yes, probably easier but it may depend on the level required to get a haccp certificate. FSSC22000 is a big step up IMO and you might find it helpful to align some things in advance, eg Prequisites.
The risk assement shows that we need a CCP during reception of raw materials because of any foreign objects such as wood splinters or metal fragments or even chemical contamination, and it also helps us to only obtain rawhide that comes from a certified slaughter house (so no rawhide from "sick" cows)
This would all be handled by Prerequisites in some haccp presentations.
After some steps, we reach the bleaching part, and the main objective of this step is to slow down the natural decomposition process of the rawhide by controlling the microorganisms present in the rawhide and also to give that white color to the roll or bone. The peracetic acid provider states that at a 100ppm concentration the p.a. has a germicidal effectiveness of 99.99%.
Probably 99.99% under laboratory conditions for a specific micro.target(s).
The practical efficiency will be defined by yr measurements.
I assume the peracetic acid is approved for RTE food use.
The following steps are mainly done by hand and the best way to avoid re-contamination it's through GMP (or at least IMO).
Then the product is placed in "shelves" then dried in an oven like the one in the picture it's just an air blower with a gas burner attached to it, during 12 hours at 40ºC then another 12 hours but at 45ºC and last, 12 hours at 50ºC. We do this process mainly to obtain a <11% humidity. (are the temperatures to low? or does it compensate with the time in the oven?)
Sorry, no experience this process. You need some data and hopefully some documentation. Offhand the temperatures seem low but i I imagine the (humidity) effectiveness will relate to the thickness of the product, etc. Residual micro-undesirables are another aspect. Picture ??
In the risk assessment I did there is not an actual risk (pathogens) that needs to be controlled during this step because of the bleaching step, the product just needs to achieve a low humidity percentage to be a shelf stable food.
See my comment on bleaching step above.
So, if the humidity it's not controlled effectively there is a chance of re-contamination? making this a CCP?
Yes, i expect this will be a CCP. A sufficiently low humidity stops microbial growth but does not eliminate any survivors from earlier steps. And similarly, afaik, a temperature of 50degC.
Metal fragments are considered as potential risks but controlled only as GMP (the blades are sharpened outside the process line and checked regularly). For the bone fragments I think I failed to explain that during the cutting step the rawhide is still soft and flexible so its easy to cut and shape as a "bone" or "roll" depending the product.
Auditors often look for a metl detector. It's become sort of traditional and especially for RTE products.But maybe not in Mexico.
Kind Regards,
Sebastian R