We are putting together a Food Safety Plan for Gravlax production on a small scale. The plan has been rejected by the Food Authority, but no reason has been offered, except that it doesn't comply with the Food Standards Code (Australia). There are 4 Gravlax products and the process is very similar for each one, with a little variation in the ingredients. Basically, salmon is purchased pre-filleted and then cured with a salt and sugar mixture in the fridge for 3-4 days. Then, the flavourings are added and the product filled into plastic containers and refrigerated. Products are transported to customer in own vehicle in a cool box. Production is undertaken in a community kitchen on Sunday nights.
We test for Listeria monocytogenes every 10 batches. We have identified the following hazards: microbiological contamination through cross contamination during product processing (hygiene of operator and equipment); pathogen presence on fish at receipt; temperature abuse of product and microbial growth post processing; temperature abuse of product and microbial growth during transport. CCPs are: purchase of salmon from reputable supplier (Supplier Approval program); temperature control post processing (<5C); temperature control and short distance to customers (<5C, less than 2 hours transport time).
I realise it's difficult without seeing the actual plan, but have we missed anything obvious here?