Can I use Consumer Cooking Instructions as a CCP?

We have decided to add Consumer Cooking instructions to our product and put it in the NRTE category.  We have an in-house cook step, but there is handling afterwards when packaging.  That puts us in the High Risk category.  I'd like to get rid of the in-house cook as a CCP because it is difficult to monitor.  Could the Consumer Cook count as a CCP if specific times and temps are stated?

Hi Aborel,

It would depend on the stated scope of yr haccp plan.

IMEX for conventional haccp, CCPs are only associated with the Facility Manufacturing Process which typically ends at the storage location of finished product prior to "shipment".

In fact the assumption that consumers are competent to correctly follow cooking instructions is used as a reason for not attaching certain microbiological CCPs to various NRTE finished products.

It seems to me that a procedure to categorise a fully cooked product as NRTE is illogical. Whether (officially) acceptable I'm unaware. I would have thought some might consider it mislabelling.

You would have zero control over the consumer cook so listing it as a CCP would be ineffective as you cannot monitor the outcome. However, it can be listed as a process control IF you are sure the consumer cooking instructions when followed are effective. I.e. where did the cooking instructions come from and can they be replicated to the desired outcome.

I do understand your logic, but I see your are from the US and cooking instructions do not hold a lot of weight if you were sued by a person and it was proven that your product had a pathogen in it.  Even raw items such as raw chicken and raw beef have zero tolerance for Salmonella and e-coli and they are raw meats.  We, as the public, should know to cook them to proper temperatures to make them safe but there are recalls every year because of positive pathogen results. 

I agree with Charles C. in that it is very hard to get your product labeled as a NRTE product if it is normally considered to be one by the public; regardless if you have instructions for customers to re-heat or not.  Whether you are USDA or FDA your product has to follow under a designated category and your HACCP Plan is expected to be designed for that category of product.  If your plan falls out of the normal expectations then you should have a solid validation study on your specific process to back it up or loads and loads of supporting articles that leave no holes to poke through.

I would not ever imagine that Customer Instructions would qualify as a CCP. Scampi makes a great point above as to why. 

If you did not cook the product to a validated temperature in your process would it still be safe to eat?  If the answer is "No" then it is a CCP step.  If the answer is "Yes" then you may have justification to remove it as a CCP but it will probably be challenging and you think you should approach very cautiously.