Good Day Everyone,
I work in a small bakery that produces primarily unbaked frozen fruit, cream, and vegetable pies. However, we do produce some baked versions of the fruit and vegetable pies and also some pies were the filling is cooked in a kettle before the shell is filled. All of this is done in a single open room with no physical separation. I have been trying to gather microbiological information on pies. However, all the info I find relates to meat pies, or other bakery items such as breads, cakes, and cookies. We consider our products to be low risk. If you bake a pie at home and you leave on the counter, the worst that happens is it molds. I have not found any info regarding a food borne illness outbreak related to a pie (does not include meat/poultry pies).
I am trying wrap my head around the FSMA requirement for Environmental Testing because they consider pies to be Ready-to-Eat. I spent 22 years in the USDA world. There if I did environmental zone testing and found Listeria, at some point I would have to do product testing.
How are other bakeries that produce fruit/cream/vegetable pies handling this requirement? Do I need to do a challenge study on baked/cream pies to see if they will support the growth of pathogens? If so, does it need to be done on every flavor or can I do it by groups of like items? These tests are expensive and the last one we had done cost nearly $10,000. We cannot afford to do this for each item that we produce.
Any suggestions you have would be most appreciated.