HACCP Plan for Gravlax process

Hi

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?

Thanks

Nick

Hi Nick 

3-4 day i fridge is not very  precise , in order to obtain uniform salt/sugar % in finished product .. ?

The listed CCP ´s  have little to do with the production process ...  Salt / sugar % & pH ?

Temperature abuse is a key element working with fish .. true ... But keep in mind Listeria grows just fine below 5 C

verify your shelf life with regards to listeria , on day 1 & end of shelf life 

1 test very 10 batch seems to be a  VERY  low frequency 

 And anything obvious ...

The project could by rejected by the Food Authority,  because  they dont want a highly listeria sensitive fish  product  in a  community kitchen on Sunday nights

The obvious risk could be to introduce listeria in the kitchen environment..

Take care

BR 

Nofish 

Hey Nofish

Many thanks for your prompt response and for the points you have made.

Much appreciated. The listeria testing program was proposed by the food authority based on the small production numbers and only producing every three weeks...

Cheers

Nick

One more hazard  perhaps -

http://www.beyondsal...isakis-and.html

I noticed one chef's recipe specified "Sushi-Grade Salmon"

Maybe the Authorities regard this as simply not appropriate for Community purposes, vulnerable consumers ?

Hi Nick,

I suggest you firstly seek a more detailed explanation from the relevant Food Authority, they are usually pretty good at giving explanations on why applications are rejected.  The main State Food Authorities (NSW, Vic & Qld) also have templates available to help you write a compliant program.  

There is also a great resource out of the US for seafood processors available at http://www.fda.gov/F.../ucm2018426.htm

and/or look for a local HACCP consultant to help you!

Thanks guys for your helpful responses - this has given us plenty to press on with. Just got a little bogged down...

Cheers