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Microbiological spec for Non Ready to Eat Frozen Product

microbiological spec ready to cook frozen product food hazard risk haccp non ready to eat coliform total plate count

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#1 farizah

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Posted 18 January 2016 - 06:42 AM

Dear my friend out there,

 

Need your help especially those who involved in non ready to eat / ready to cook food industry. May I know where you refer to decide on microbiological spec for non ready to eat frozen product? In most of food regulation that i read include my country, I only found standard for fish product ready for consumption in which ready to cook fish product is excluded right?? 

 

Recently, i obtain microbe analysis for my product. What put me in headache is the microbe content is to high especially for TPC( 57 000cfu/g )and coliform(150MPN/g). If i refer to microbiological standard for fish product ready for consumption which is TPC (106 per g) and Coliform ( 50 per g), my product is already out of specification.

 

Is it my product still safe to be consumed and sell to the consumer since the hazard will be kill at cooking step by the consumer. Or I need to work again on my HACCP risk analysis.

 

For your information our product is Fish Otak is kinda like fish cake. Roughly the production step is like this  : mix all the ingredient ( last ingredient added are raw fish cube, egg, coconut milk and starch ) --> shape --> put in the frozen storage -18C  --> vacuum packing -- frozen storage -18C. The product need to be cooked before consume. I set the frozen storage as one of our CCP.

 

Help  meee  :helpplease: :helpplease:

 

 

Thanks & Rgds

Farizah

 



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#2 TAN85

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Posted 18 January 2016 - 09:05 AM

Hi there,
My country doesn't have it's own standards either,so we either use the client's s
Standard or an international one like Codex. Those will usually have some micro guidelines. It is also a good idea for you to examine potential issues from the ingredients you are using (ie salmon fresh eggs- just assuming).
There could also be published research about micro in your product, otherwise use well known risks associated with that
Product.
As it is not RTE the micro may be less stringent however you do need to make sure you are providing a safe product. Take into consideration also that
Some people may not follow cooking instructions properly either.


"Do not go where the path may lead, go instead where there is no path and leave a trail.."


#3 Charles.C

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Posted 18 January 2016 - 06:23 PM

Hi farizak,

 

I assume yr product is for local consumption.

 

If so it presumably has to compy with yr local micro.regs regardless of whether you disagree with the limits or not. In fact neither TPC nor coliform are usually regarded as directly safety-related.

 

it also appears you only sampled/analysed one unit. This is normally not a recommended procedure although may be unavoidable if so specified in the regulatory requirements.

 

57,000 is greater than 1 million ?.

 

As to the basis of microbiological specifications here is the Codex viewpoint -

 

Attached File  Codex establishment of micro.criteria, 1997.pdf   145.26KB   121 downloads

 

And another Codex related document (2007) -

 

Attached File  Codex, micro. risk management.pdf   229.41KB   94 downloads

 

Somewhat negative viewpoints also exist, eg -

 

Many of the microbiological examinations of foods both by industry and regulatory agencies are meaningless and a waste of time and resources. Indiscriminate application of microbiological testing and criteria should be avoided. As the existence of a MC always requires some degree of microbiological testing, it needs very careful consideration, before any MC is established.

http://www.fao.org/d...3e/y4743e0n.htm

 

PS - IMO it is illogical to compare yr data with that of the spec for a RTE product.

 

IMEX for frozen raw fish, yr data for TPC/coliform would not be considered objectionable. Presence of pathogens such as Salmonella would be though.

Some suggested reference data (1986) for frozen raw fish is on pgs 190-191 of this document - 

Attached File  microorganisms in foods 2,pt2.pdf   802.97KB   96 downloads

 

The additional components are all potential sources of contamination, both intrinsic (eg raw eggs) and handling (eg  coconut milk).

You might consider comparing the coliform level in finished product to that in the input materials, a significant increase could indicate a need for more hygiene control such as time/temperature aspects.

 

PPS - also note this usfda comment for vac.packed frozen raw fish -
 

 

Frozen, reduced oxygen packaged raw, unpreserved fish and unpasteurized, cooked fishery products

For frozen, reduced oxygen packaged raw, unpreserved fish (e.g., frozen, vacuum-packaged fish fillets) and frozen, reduced oxygen packaged, unpasteurized, cooked fishery products (e.g., frozen, vacuum-packaged, unpasteurized crabmeat, lobster meat, or crayfish meat), the sole barrier to toxin formation by C. botulinum type E and non-proteolytic types B and F during finished product storage and distribution is freezing.   Because these products may appear to the retailer, consumer, or end user to be intended to be refrigerated, rather than frozen, labeling to ensure that they are held frozen throughout distribution is critical to their safety.

Controls should be in place to ensure that such products are immediately frozen after processing, maintained frozen throughout storage in your facility, and labeled to be held frozen and to be thawed under refrigeration immediately before use (e.g., “Important, keep frozen until used, thaw under refrigeration immediately before use”). Frozen, reduced oxygen packaged products that are customarily cooked by the consumer or end user in the frozen state (e.g., boil-in­bag products and frozen fish sticks) need not be labeled to be thawed under refrigeration. For purposes of hazard analysis, other frozen products that do not contain the “keep frozen” statement should be evaluated as if they will be stored refrigerated because the consumer or end user would not have been warned to keep them frozen.

 


Edited by Charles.C, 19 January 2016 - 12:28 AM.
expanded

Kind Regards,

 

Charles.C


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#4 farizah

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Posted 19 January 2016 - 01:24 AM

Dear Tan85 and Charles,

 

Really thanks for your reply and input on this issue. Seems like there is a lot of thing to consider when set up microbe criteria for non RTE product :headhurts: because before this i work on RTE product that can directly refer to limit state by regulation. Anyway thanks!! i need to start study again and will comeback later :spoton:

 

So Charles, I just want to confirm with you that the indicator for non safe food product is only the major pathogen like E.coli,S.Aureus, Salmonella and Vibrio ( raw fish). Others like coliform is still ok if out specification. Is it correct??

 

Thanks

Farizah



#5 Dr.Khan

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Posted 19 January 2016 - 01:54 AM

Hi Farizah 

 

Please visit the following link from FAO site it will give the micro limits for fresh fish products.

 

www.fao.org/docrep/003/t1768e/t1768e04.htm

 

Kind regards

Humaid Khan

MD- Halal International Services



#6 farizah

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Posted 19 January 2016 - 08:06 AM

Hi Humaid Khan

 

Thanks for the link :spoton: . I have read it, really useful..



#7 Charles.C

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Posted 19 January 2016 - 10:55 AM

Hi farizah,

 

So Charles, I just want to confirm with you that the indicator for non safe food product is only the major pathogen like E.coli,S.Aureus, Salmonella and Vibrio ( raw fish). Is it correct??

 

Many other pathogens can be associated with food such as Shigella, L.monocytogenes, C.botulinum, etc, etc. (eg see previous links)

So the answer is No.

 

Note 1 – (a) Vibrio is a family, a few species of which are human pathogens in a seafood context, (b)  most strains of E.coli are not pathogenic, © pathogenic S.aureus (or more precisely its toxin) is routinely suffixed as necessarily coagulase positive (although some caveats may exist).

Note 2 – “indicator” is a kind of reserved terminology in the current context, eg –

https://en.wikipedia...icator_bacteria

 

 

Others like coliform is still ok if out specification. Is it correct??

From a business POV it may depend on the contractual sampling/analysis agreement.

Within a set of official micro. nmMc accept/reject criteria  the answer is typically No.

 

@ Humaid Khan – nice link / info. It's a precursor [1994] to that linked in my post [2003] but seems the data never got updated so both  "official"  Tables  are probably now well obsolete, eg for USA, afaik, raw frozen fish is not routinely tested for any of the stated 1,6,10. On the other hand it is tested for 7.


Kind Regards,

 

Charles.C


#8 sivac191

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Posted 31 March 2016 - 10:22 AM

Dear my friend out there,

 

Need your help especially those who involved in non ready to eat / ready to cook food industry. May I know where you refer to decide on microbiological spec for non ready to eat frozen product? In most of food regulation that i read include my country, I only found standard for fish product ready for consumption in which ready to cook fish product is excluded right?? 

 

Recently, i obtain microbe analysis for my product. What put me in headache is the microbe content is to high especially for TPC( 57 000cfu/g )and coliform(150MPN/g). If i refer to microbiological standard for fish product ready for consumption which is TPC (106 per g) and Coliform ( 50 per g), my product is already out of specification.

 

Is it my product still safe to be consumed and sell to the consumer since the hazard will be kill at cooking step by the consumer. Or I need to work again on my HACCP risk analysis.

 

For your information our product is Fish Otak is kinda like fish cake. Roughly the production step is like this  : mix all the ingredient ( last ingredient added are raw fish cube, egg, coconut milk and starch ) --> shape --> put in the frozen storage -18C  --> vacuum packing -- frozen storage -18C. The product need to be cooked before consume. I set the frozen storage as one of our CCP.

 

Help  meee  :helpplease: :helpplease:

 

 

Thanks & Rgds

Farizah

hi 

 

You can find the Specification .

Please receive the Microbial Reference Criteria for Food As an attachment.

Attached Files



#9 Charles.C

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Posted 31 March 2016 - 04:28 PM

Hi Sivac,

 

Thanks for the attachments.

I noted that these were compiled for NZ in 1994, 1995 respectively. A lot of the info. is still relevant but some areas (and Reg.data) need caution, eg the "L.mono." section.

It is indeed difficult IMEX to find detailed up-to-date compilations of micro.specs.

Many countries (understandably) do not offer Regulatory data in English.


Kind Regards,

 

Charles.C






Also tagged with one or more of these keywords: microbiological spec, ready to cook, frozen product, food hazard risk, haccp, non ready to eat, coliform, total plate count

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