Help - Caesar Dressing HACCP Plan

Hi everyone!

I am working on developing a HACCP Plan for a Caesar Dressing with pasteurized, liquid egg yolk as one of the notable ingredients. The egg yolk would be pasteurized by our supplier, so it would not be done on-site.

I'm having trouble determining CCPs, as the ingredients would just be mixed together, bottled in plastic jugs, and refrigerated for storage. Would mixing be a CCP step if the pH of the mixture (pH < 4.1) inactivates Salmonella spp.? This would be where we measure pH to monitor this. 

Any advice would be appreciated. Thanks!

Be careful with that pH limit, FDA's guidance since 2011 has used 3.7 as the survival limit for salmonella.

https://www.fda.gov/...A/UCM517405.pdf

Haven't done dressings, but your CCP's will be determined based on your process and controls, so what does your risk assessment say? Off the top of my head, looking at your post, I would examine the following process points closely:

1. Time/Temperature limits when you introduce perishable ingredients into your "mix"  and how long it takes to get the final product down to refrigeration temperature. The egg being a great example here.

2. Final pH of the product as you stated above. However if the product is refrigerated you're also controlling salmonella/E. coli/Staph that way, so that's not necessarily your target organism. pH of <4 would be a good control step for Listeria growth, which would be of concern in your product if you didn't have this pH level, so it's a control step there.

3. Allergen control might be an issue if you've got milk/egg running around and potentially wheat/soy/mustard/sesame in spice blends.

Hi there, and thanks for the reply!

First off: thanks for the document link! That's a great head's up about the pH limit. I've been struggling to find the same information online via the Health Canada/CFIA websites. While the product isn't intended for export to the USA, the information certainly works as validation, so it's much appreciated.

What I'm uncertain about is whether or not the product's temperature (in it's final state) matters... It would be mixed in an environment that is somewhere between 11-21°C (<70°F), which is the temperature of that particular production room. The product is technically shelf stable after it's been mixed together by nature of the pH alone. (Which, in initial testing has yielded results of pH 3.5/3.6) On our end, storage at refrigeration temperatures is more to extend the shelf life than to control for pathogen growth...so chilling it within a certain time is unnecessary? Maybe my thought process is missing something vital.

The allergen control aspect has been noted! 

Hi everyone!

 

I am working on developing a HACCP Plan for a Caesar Dressing with pasteurized, liquid egg yolk as one of the notable ingredients. The egg yolk would be pasteurized by our supplier, so it would not be done on-site.

 

I'm having trouble determining CCPs, as the ingredients would just be mixed together, bottled in plastic jugs, and refrigerated for storage. Would mixing be a CCP step if the pH of the mixture (pH < 4.1) inactivates Salmonella spp.? This would be where we measure pH to monitor this. 

 

Any advice would be appreciated. Thanks!

Hi CT,

IMO you need to fully understand/research the safety-related fundamentals of yr product, notably the biological ones. From a quick look,  pH-related regulations may vary depending on various characteristics, eg location, opinion etc.

JFI -
mayonnaise.png   58.63KB   6 downloads

(ca 2011)

Can see this older thread -

http://www.ifsqn.com...dressing-haccp/

(esp the files in post 8, 10 regarding significant hazards)

Another book extract  -

dressings.png   30.93KB   4 downloads

(ca 2005)

this attached US oriented article from 2006 has pH limits for salad dressing higher than as noted in Post 2 (see PS below)

food haccp,2006.pdf   506.22KB   127 downloads

For 3 suggested control parameters can also see appendix this (ca2001) FDA article which may/may not be obsolete -

Evaluation-and-Definition-of-Potentially-Hazardous-Foods,2001.pdf   1.63MB   85 downloads

PS - @3F/CT, I think the pH limit (as indicated in Post 2) is typically not an independent number. The value also needs to be related to the specified hazard and product composition (see the refs in my link above). I note the Salmonella/pH value 3.7 in 2F's link but also the Table's caveat "These values may not apply to your food or processing conditions".

i was unable to find any confirmation as to what pH value FDA are currently specifying for this range of product.  Are there any  specific links available ? What is the typical composition of Caesar dressing ?

addendum

This is the most recent (2016), possibly(?) relevant, magazine article i could find -

Salad Dressings,2016.pdf   628.33KB   144 downloads

(the CFR ref. is the sole "official" quant.pH value I have seen for "dressings")

I also noticed this rather nice pictorial survey of various types of salad dressings/mayonnaise which suggests  2CCPs for Caesar Dressing but without giving any critical limits for the first one. One CCP is as predicted already (~ preparation) but the 2nd one for storage at low temperatures seems questionable since this product should surely be shelf stable, ie non-TCS (unlike the labelled data?).(CQP might be more appropriate?).

haccp CCPs Caesar Dressing.pdf   1.11MB   183 downloads

And one more, not recent, which clearly regards salad dressings having pH values within its stated range as shelf stable

Guidance for PHF-TCS Foods,2006.pdf   1.51MB   124 downloads

(see Pg12)