14 replies to this topic

[J MSc]

Hi,

 

I would be very thankful if someone could tell me how to explain to a BRC auditor that heating fish to 63 degrees is a lot and that 70 degrees is too much if you want to keep a pleasant texture.

 

According to the BRC Food safety standard food has to be heated to a core temperature of 70 degrees C for 2 minutes (or equivalently) to be called cooked or RTE.

 

According to FDA fish has to be heated to a core temperature of 63 degrees C to be safe.

 

 

 

 

 

 

[trubertq]

Welcome to the forum J MSc

 

We'd need to know your process to be able to help fully, but in my experience if you can show, through validation and scientific literature and shelf life studies that your product is achieving the necessary decimal reduction in pathogens during your cooking process then it should be ok.

 

The zoning guide which is what you are referring to ( I think) states " have all vulnerable products received, prior to entry into the area, a heat treatment equivalent to 70°C for 2 minutes.

 

Nowhere in the standard itself does it state times or temperatures. 

An auditor can't tell you how to run your process but you must be able to prove to an auditor that the process which you are using achieves the pathogen kill you require.

[trubertq]

Appendix 3 gives you a table of equivalent processes to achieve 70°C for 2 minutes.

 

So either lower temp for longer time or higher temp for less time.

[Charles.C]

Hi,

 

I would be very thankful if someone could tell me how to explain to a BRC auditor that heating fish to 63 degrees is a lot and that 70 degrees is too much if you want to keep a pleasant texture.

 

According to the BRC Food safety standard food has to be heated to a core temperature of 70 degrees C for 2 minutes (or equivalently) to be called cooked or RTE.

 

According to FDA fish has to be heated to a core temperature of 63 degrees C to be safe.

 

The reason is likely due to a different target microbial species. (Salmonella vs L.mono.)

[J MSc]

Thank you for your input!

 

We have never seen Salmonella in our fish raw material or in our finished products.

We have never seen L. monocytogenes above 2 log cfu/g in our fish raw material or in our finished products. According to EU regulation 2073/2005 L. monocytogenes in food should be below 2 log cfu/g.

L. monocytogenes is the only microbiological hazard mentioned for fish in a hazard guideline from the Swedish National Food Administration.

 

1. Do I still have to prove pathogen kill for our process? Prove that the core temp reaches 63/70C or equiv.?

 

2. Do I still have to prove kill for our cooking instructions on our finished products? Prove that the core temp reaches 63/70C or equiv.?

 

I ask these questions because I don´t want to have to choose between safe products (safe in the sence that we have to prove a core temp of 63/70C or equiv.) and tasty products. To heat our frozen products to a core temperature of 70 C or equiv. leads to a not very tasty result.

[Charles.C]

Hi JMSc,

 

3 comments –

 

(1) The specific answer(s) may depend on yr specific process as mentioned  in Post 2.

(I get the impression that you are mixing queries for both non-RTE and  RTE)

 

 (2) As you noted FDA's official publication quotes a value of 63degC for finfish which I anticipate is based on Salmonella. Curiously this micro.choice / temperature is not in line with the FDA’s Fishery Guide manual (which I thought was the FDA Guideline) which focuses on L.mono in a similar way to EC and as described by Trubertq. Reason for discrepancy  unknown to me.

 

(3) The typical Regulatory hierarchy for local food consumption in most (all?) countries in EC is afaik - Local >> EC. The result is a mixture of target micro. species across EC.

I assume that the Swedish Reg. you quote is appropriate for yr product/process so that L.mono will be the micro. species of interest.

 

Assuming a typical (eg not ROC product) RTE item I agree with previous comments.

 

(1) Yes -BRC7 sec.6, and presumably sec.2.9

 

(2) No since RTE finished product should not require full cooking instructions.

  

BRC7 Standard also has –

 

It should be noted that where the product has cooking instructions for the consumer that are equivalent to a full cook, then the product may be considered as low risk. In these situations, the site is expected to have a full validation, which the auditor can refer to, demonstrating that the cooking instructions are appropriate and that the product will achieve the correct temperature/time when the cooking instructions are used.

 

I understand yr comment regarding tasty and I daresay many people will agree with you. Unfortunately Regulatory decisions prioritize on Safety. I guess events like Jack-in-the-Box provide a good reason.

[trubertq]

I work mainly with Seafood and Listeria monocytogenes is the organism of most concern to my clients. 

 

I presume you do finished product microbiological testing?

 

Wouldn't this verify that your product is within the microbiological parameters for the country within which your product will be sold?

 

I also presume you have carried out shelf life trials which could also be used as verification of your process?

[GMO]

Thank you for your input!

 

We have never seen Salmonella in our fish raw material or in our finished products.

We have never seen L. monocytogenes above 2 log cfu/g in our fish raw material or in our finished products. According to EU regulation 2073/2005 L. monocytogenes in food should be below 2 log cfu/g.

L. monocytogenes is the only microbiological hazard mentioned for fish in a hazard guideline from the Swedish National Food Administration.

 

1. Do I still have to prove pathogen kill for our process? Prove that the core temp reaches 63/70C or equiv.?

 

2. Do I still have to prove kill for our cooking instructions on our finished products? Prove that the core temp reaches 63/70C or equiv.?

 

I ask these questions because I don´t want to have to choose between safe products (safe in the sence that we have to prove a core temp of 63/70C or equiv.) and tasty products. To heat our frozen products to a core temperature of 70 C or equiv. leads to a not very tasty result.

 

The time / temperature combinations are to assess which zoning your factory has so if below that temperature it can be high care not high risk (controls are basically very similar anyway.)  So I think this is all a bit of a red herring...

 

Sorry I couldn't resist...

 

As for whether cooking at the lower temperature is safe or not?  You've almost answered the question yourself IMO.  You have a 2 log presence sometimes in the raw material.  The only answer you need to give is whether the process you are undergoing is sufficient to kill the worst case scenario of Listeria monocytogenes. present in your raw material.  You might need to validate the cooking process yourselves for this.  I would also ensure you target not detected in the finished product as the max 100cfu g^-1 limit is insufficient if growth is possible (which in cooked fish it probably is). 

I would also look at my chill chain even in the raw state and ensure it's as cold as possible.  Although Lm can grow at chill temperatures, the colder it is, the slower the growth...

 

And verification will be key.  This process will be "closer to the wire" than a traditional 6 log reduction cook.  I know others have said there are equivalent temperatures listed, however, the times are significantly lengthened.  It is possible though to have Listeria monocytogenes absence at lower heat / time combinations but you need more careful raw material monitoring.  A good example would be milk processing.  This is not a traditional 6 log "cook" (the holding times are too short) but part of your controls are overall micro loading of the raw materials which are trended and if exceeded supply is stopped.

 

Not sure if that's of any help?   Good luck.

[Charles.C]

Hi GMO,

 

I got the impression that all the finished products are frozen, some raw, some RTE. It's sadly unclear. MAP / Vac. /ROC if frozen/unfrozen similarly no idea.

 

Theoretically, 6D for L.mono at 63degC requires minimum 17 minutes (FDA Fishery Guide). (alternatives are not [BRC] ruled out, BRC7, Pg 98)

 

No idea of the scope/specific regs of Swedish micro. regs. These will presumably take precedence over "other opinions" for local consumption.

 

As you say, chilled items are "something else" altogether.

 

Pity the info. is so limited.

[J MSc]

Thanks a lot for all the answers!

 

So to give you some more detail about our process and to sum things up:

 

We will be sawing standard 7,5 kg frozen fish blocks into portions. The frozen portions will be steam cooked to a core temp of 63 degrees C and then immediately frozen in a gyro freezer and packaged. This product will be delivered to the customer as a frozen Ready to Heat product -18 degrees C.

 

-The fish blocks have never shown L.mono levels above 2 log cfu/g.

-The limit for L.mono for RTE-products that do not support the growth of L. mono is 2 log cfu/g within the EC. Frozen products -18 degees C do not support growth of L.mono.

-The customer will only heat the product to serving temperature.

 

Do you agree that if we check the level of L.mono in the fish blocks and the end product to assure that it is below 2 log cfu/g, and check that we reach a core temp of 63 degrees C in our steam cooking process that this would meet the requirements of BRC for a Ready to Heat Product?

 

By the way: What is a "ROC-product"?

 

Kind Regards

J MSc

[Charles.C]

hi JMSC,

 

What does a "ready to heat" product actually mean ? i anticipate = scientifically RTE with/without further heating by customer ?

 

for RTE, afaik, you need 70degC/2min minimum or equivalent unless yr local reg states otherwise and local consumption only.

 

i suspect the 2log you mention is at the end of shelf-life ?(ie includes distribution chain, etc etc)

 

ROC = reduced oxygen content, eg vac.pack

[J MSc]

Hi Charles,

 

BRC 7, Page 114, "Ready to heat food - Food designed by the manufacturer as suitable for direct human consumption without the need for cooking. The heating of the product is intended to make the product more palatable." Maybe better to call it RTE?

 

For a frozen product it should be OK to check the level of L.mono (or any microbe) in the end product directly after freezing since it will not rise during shelf-life?

 

"ROC", what is this?

 

Kind regards

J MSc

[J MSc]

Hi Charles,

 

How do you edit your already posted replies?. Can I do that too?

[Charles.C]

Hi Charles,

 

(1) BRC 7, Page 114, "Ready to heat food - Food designed by the manufacturer as suitable for direct human consumption without the need for cooking. The heating of the product is intended to make the product more palatable." Maybe better to call it RTE?

 

(2) For a frozen product it should be OK to check the level of L.mono (or any microbe) in the end product directly after freezing since it will not rise during shelf-life?

 

(3) "ROC", what is this?

 

Kind regards

J MSc

 

 

(1) This is likely to be a local regulatory option.

(2) A risk assessment is involved, eg it may depend on the actual data and its accuracy (eg sampling/variation/analysis). It is correct that L.mono. will not grow at -18degC. Afaik, legally, the product specification is typically required to be fullfilled at end of shelf life (part of shelf-life validation).

(3) ^^^^^

[GMO]

Thanks a lot for all the answers!

 

So to give you some more detail about our process and to sum things up:

 

We will be sawing standard 7,5 kg frozen fish blocks into portions. The frozen portions will be steam cooked to a core temp of 63 degrees C and then immediately frozen in a gyro freezer and packaged. This product will be delivered to the customer as a frozen Ready to Heat product -18 degrees C.

 

-The fish blocks have never shown L.mono levels above 2 log cfu/g.

-The limit for L.mono for RTE-products that do not support the growth of L. mono is 2 log cfu/g within the EC. Frozen products -18 degees C do not support growth of L.mono.

-The customer will only heat the product to serving temperature.

 

Do you agree that if we check the level of L.mono in the fish blocks and the end product to assure that it is below 2 log cfu/g, and check that we reach a core temp of 63 degrees C in our steam cooking process that this would meet the requirements of BRC for a Ready to Heat Product?

 

By the way: What is a "ROC-product"?

 

Kind Regards

J MSc

 

I don't think you should be worrying about BRC, you should be worrying about food safety as a whole.  The BRC guidelines as I said before are only to define the care status of your area.  What scares me witless is that your process appears to have no validation that your cook is effective at reducing Listeria to an acceptable level (whether or not 100 cfug-1 is acceptable is another issue I will get to next.)  This is literally the point of HACCP to design the process so it's effective not to test as your first control.  Testing should only be verification.  You appear to be missing this step out entirely? 

As I explained before you need to validate your cooking process to see how many log reduction you can expect, that is step 1.  Every other question is a moot point until you do this and however much testing you do, you cannot prove your product is safe.  Why?  Because you may not be selecting sufficient samples to be able to confirm you don't have microbiological spikes.  You may have cooking "cold spots" you're not aware of within your cooking vessel.  You are likely to have some fish which are more heavily contaminated than others.

 

Onto the next question... is 100cfug-1 safe?  For vulnerable groups, possibly not.  This may be the legal limit but if you had someone made ill by your foodstuff (or allegedly made ill) what defence do you have?  Nowadays, most competent authorities are doing full genome sequences on pathogens.  If, say, you had a product where you had a spike of Listeria within a product and it matched the strain present, albeit at lower levels in your other products?  Or the authorities accept your explanation that it's always present in the ingredient but see how widely distributed it is in your product and conclude you're not in control... I can't see you winning that case even if you ignore the ethical side of potentially killing someone.

The last point is acceptance of levels in the product can cause companies to fail to see in factory sources of contamination which are very likely in most chilled factories.  Be very, very careful at introducing a "listeria is ok" culture.  Is a gyro freezer like a spiral freezer?  They are notorious as places listeria can harbour...

The last point to consider is the consumer and potential abuse.  Sure you intend that they will simply warm and serve but what if they warm then serve cold in a buffet?

I know I'm a worrier but this would give me sleepless nights.