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#1 DRFSM

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Posted 19 April 2018 - 08:59 AM

Greetings all, been researching gravalax for few days now and although there is many recipes on making it at home, none of these talk about CCP's or controls in palce for Listeria from a production point of view.

 

I have seen many vac packed gravalax with dill weed products on the market but can not for the life of me figure out how its done...

 

Listeria is the main issue as there is no listeria cook. salmon used is most certainly farmed. but how do they get around listeria? do they control salt / sugar ratio to reduce Aw below 0.92? this would not kill listeria but rather control it if it existed right?

 

so what am i missing? is it just short as hell shelf life?

 

any help appreciated.



#2 Quality Ben

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Posted 19 April 2018 - 11:03 AM

Hi DRFSM,

 

I am involved in the production of Gravadlax (and cold smoked salmon) in a commercial basis and it's all about hurdles my friend.

Forget about aw as a measure as grav and cold smoked is generally not below 0.96 ...ish......depending on the flavour profile / sensory characteristics you are looking for. Your better off using salt in water phase as a measure.......yes, it is really just a tertiary measure whereas aw is a primary measure but like I mentioned - aw doesn't work. Also keep in mind that using salt in water phase is normally only around c.bot control rather than L.monocytogenes and mono will survive up to around 11% salt in water phase anyway....and this would be salty / dry as hell! 

 

Seeing as Gravadlax doesn't have the added hurdle of smoking / phenols like cold smoke - you need to ensure all your other hurdles are just as; if not more robust.....GMP around processing of your raw materials and handling / processing. Like most pathogens - Listeria is not found in the flesh of the fish....you introduce it from; either under the scales or in the gills / gut area from your raw material or from your processing environment / handling.... I can't stress this part enough. If your looking at making this commercially and need to prove Listeria free then positive release batches are recommended as best practice. 

 

Your brandy and salt do a lot of the work here - finding the right levels to get a salt in water phase of around 5% seems to work well - of course this all depend on your initial bacterial load (which is where your previous hurdles come in to play). 

 

Each (seemingly) small hurdle plays a big part in the finished product........like the old saying goes...'Sh*t in = Sh*t out'!

 

Hope this rambling helps in some way....it's late  :smile:



#3 DRFSM

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Posted 20 April 2018 - 06:12 AM

Hi Ben,

 

Yeh alot of what your saying makes sense to me, although my raw material supplier states Listeria free in their specification i have raised the point with them that this is very hard to justify from their end simply because of gills and gut area contamination.I have worked with Aw and WPS in our hot roasted salmon products with great success by controlling brine strenghs and times etc but like you mention this largely helps to validate controlling C.bot especially in vac pack with a listeria kill step its good safe product with descent shelf life.

 

Attaining WPs around 5% is achievable  but im not convinced anyone can is able to state 100%~ listeria free at raw material end (the fish it self) and thus once exposed to processing environments its going to be present but controllable to a acceptable level from a hygiene point of view.

 

To quote you how ever sh*t Sh*t out if it isnt 100% free at the start then you got it all the way through and this would be true also of anyone doign their own gravlax at home surely...

 

When you say positive release at what stage were you referring? are you talking about testing the fish batch prior to its use for gravalax? then on 1good result using it going forward assuming all hygiene controls in place etc..?

 

I might add that we would like to cure salmon also with a smoking process for flavour but were looking at chilled cold smoking process rather than traditional smoke at what ever temperatures lol.....



#4 Charles.C

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Posted 20 April 2018 - 07:22 AM

Some more Gravlax (so many names !) thoughts/difficulties here -

 

http://www.ifsqn.com...ravlax-process/

 

https://www.theguard...d-salmon-recipe

(many, many cooking references in Google)


Kind Regards,

 

Charles.C


#5 DRFSM

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Posted 20 April 2018 - 11:19 AM

Some more Gravlax (so many names !) thoughts/difficulties here -

 

http://www.ifsqn.com...ravlax-process/

 

https://www.theguard...d-salmon-recipe

(many, many cooking references in Google)

 

Yeh a quick search and i found that thread a few days ago too and looked at the links within it but still no real idea of how to get passed EHO requiring 100% listeria free when the raw material contains it by default... no listeria kill step then how is it done?

 

previous gentleman suggested positive release method however as i stated my supplier claims listeria free but it my samples show this is only true 60% of the time. and appears to be the case with all the suppliers i have seen all being farmed salmon at the least.

 

i mean even Sushi grade could be contaminated with Listeria....how is that safe to sell with no kill step???

 

 

I would love to see a) a Gravala HAACP process flow detailing CCP's  but all you general find online is home DIY recipes for making it nothing on a production scale. and even your second link doesn't mention anything about listeria. that i saw...



#6 SausageGuy

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Posted 20 April 2018 - 11:30 AM

Maybe this will help?

 

https://www.ncbi.nlm...les/PMC3768386/



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#7 Charles.C

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Posted 21 April 2018 - 08:25 AM

Yeh a quick search and i found that thread a few days ago too and looked at the links within it but still no real idea of how to get passed EHO requiring 100% listeria free when the raw material contains it by default... no listeria kill step then how is it done?

 

previous gentleman suggested positive release method however as i stated my supplier claims listeria free but it my samples show this is only true 60% of the time. and appears to be the case with all the suppliers i have seen all being farmed salmon at the least.

 

i mean even Sushi grade could be contaminated with Listeria....how is that safe to sell with no kill step???

 

 

I would love to see a) a Gravala HAACP process flow detailing CCP's  but all you general find online is home DIY recipes for making it nothing on a production scale. and even your second link doesn't mention anything about listeria. that i saw...

 

Hi DRFSM,

 

At one time the FDA required all raw imported seafood to be L.mono undetectable. You can guess the consequences. Requirement was rapidly "deleted".

 

Any assurance of negative L.mono in  raw seafood products is likely to be Russian Roulette unless it's straight from the deep sea or maaaybe with a further  impeccable subsequent processing.

 

I noted literature comments that farming salmon may or may not be an environmentally pristine activity. :smile:


Kind Regards,

 

Charles.C


#8 DRFSM

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Posted 23 April 2018 - 08:00 AM

Hi DRFSM,

 

At one time the FDA required all raw imported seafood to be L.mono undetectable. You can guess the consequences. Requirement was rapidly "deleted".

 

Any assurance of negative L.mono in  raw seafood products is likely to be Russian Roulette unless it's straight from the deep sea or maaaybe with a further  impeccable subsequent processing.

 

I noted literature comments that farming salmon may or may not be an environmentally pristine activity. :smile:

Yeh Russian roulette is a good analogy for sure... Having read Rickys link and many like it however it seems that there is still no information on how these manufacturers are getting round the issue?

 

assume product contamianted from raw material phase. Even if...processing curing methods packaging methods were all sterile the raw material would still be contaminated.... yet go to a supermarket and there it is on the shelf!!!

 

I wonder if there is a shelf life limiting factor with Listeria for UK?? the local fishmongers around me (who are equally baffled) all sugest no greater than 21 days shelf life but the studies i have ready such as Rickys below are for 90 days!!!!

 

 

Perhaps in reference to Quality Ben, producing a batch of gravad lax from positive released raw material salmon i.e testing it for listeria then on negative result using it for gravadlax would be the way forward... but then if you purchase raw material as such and it fails you loose money from the raw material unless you can use it in a product that has a Listercidal process.

 

Maybe this will help?

 

https://www.ncbi.nlm...les/PMC3768386/

Thank you for the link Ricky very informative...

 

 

I would love to hear back from you Quality Ben.... :)



#9 Scampi

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Posted 23 April 2018 - 02:24 PM

Perhaps these articles may help??

 

www.fishfarmingexpert.com/article/how-much-listeria-can-be-in-fresh-salmon-for-it-to-be-eaten-raw/

 

https://onlinelibrar...59.2008.00118.x

 

https://www.research..._of_listeriosis

 

http://medcraveonlin...MB-06-00149.pdf

 

www.canada.ca/en/health-canada/services/food-nutrition/legislation-guidelines/policies/policy-listeria-monocytogenes-ready-eat-foods-2011.html


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#10 Quality Ben

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Posted 29 April 2018 - 11:00 PM

Yeh Russian roulette is a good analogy for sure... Having read Rickys link and many like it however it seems that there is still no information on how these manufacturers are getting round the issue?

 

assume product contamianted from raw material phase. Even if...processing curing methods packaging methods were all sterile the raw material would still be contaminated.... yet go to a supermarket and there it is on the shelf!!!

 

I wonder if there is a shelf life limiting factor with Listeria for UK?? the local fishmongers around me (who are equally baffled) all sugest no greater than 21 days shelf life but the studies i have ready such as Rickys below are for 90 days!!!!

 

 

Perhaps in reference to Quality Ben, producing a batch of gravad lax from positive released raw material salmon i.e testing it for listeria then on negative result using it for gravadlax would be the way forward... but then if you purchase raw material as such and it fails you loose money from the raw material unless you can use it in a product that has a Listercidal process.

 

Thank you for the link Ricky very informative...

 

 

I would love to hear back from you Quality Ben.... :)

 

 

Hi DRFSM,

 

I don't think you can guarantee listeria free 100% with no kill step (I don't personally think you can 'guarantee' food safety in any real sense) - but rather ensuring the risk and bacterial load ...if present....is as low as you can make it.

Regulations require ND yes ....and your hurdles should make this achievable seeing as you wouldn't test every single product from every batch.

 

We use positive release on the other end....completed product......we are not able to positive release on incoming RM as it is our farmed product.....no way to reject (read....not allowed....haha).

And our testing has shown that we do bring in l.mono on the fish (seeing as it is environmental this is no surprise) but in very small amounts and always under ~3 cfu/g - when we see it in larger loads it generally means contamination post harvest.

Seeing as it is bought in in small amounts....the hurdles are set up to A) ensure no further contamination from processing etc and B) to ensure that the small amounts that MAY be present are not given the chance to out compete other natural flora (whole fish gutted and cleaned well with potable water that is 'spiked' to increase chlorine to approx 3ppm. Fillets go under a spray bar after they come off the frame (potable water) and then the product sits in a chilled environment (under 5c) until ready to process into Grav.

The grav mixture is the next big hurdle - salt, sugar, alcohol, etc to attain a WPS of ~3.5% - the product is then placed on hold for testing. We are generally getting TPC of between 100 and 500 cfu at start (higher than cold smoked) and find mono about twice per year (process grav twice per weeek .....so give or take....2% of the time).  Let me know if this helps at all .... there are also some things you can do with batch testing to ensure you are not looking at dumping large amounts of product.....WIP vs finished goods scenarios.....and potential for hot smoking so then you can use in further byproduct etc....



#11 Charles.C

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Posted 30 April 2018 - 03:55 AM

Hi DRFSM,

 

A few more comments -

 

(1) I'm not sure as to the consumer location of the product discussed in OP (UK?)  but, apropos Q.Bens input, I noticed this comment in  attached FSANZ document (undated,ca 2013) -

 

2. RTE foods not receiving a listericidal process
 
Some foods do not receive a listericidal process during manufacture (e.g. smoked finfish; gravadlax finfish; fresh cuts) and ensuring product safety relies on minimising or reducing contamination during primary production, processing and distribution, and limiting growth through maintaining the cold chain and restricting shelf life. Occasional low level contamination of such products by L. monocytogenes may be unavoidable but may not present a risk if growth cannot occur or is limited within the stated shelf life.

If evidence can be provided that the level of L. monocytogenes is limited (less than 100cfu/g) throughout the stated shelf life of these foods, then a limit of 100 cfu/g applies for the purpose of Standard 1.6.1.

Attached File  Guidance on the application of L.mono, micro. criteria, in RTE food.pdf   289.24KB   10 downloads

(also see -

http://www.foodstand...-eat-foods.aspx

 

UK may have a different Regulatory viewpoint of course (= EC? = ?)

 

(2) If a ND criterion does apply then I guess the sampling situation becomes analogous to Salmonella detection in Foods. Very high sampling levels (much greater than the typical Regulatory levels)/negative results will be required to statistically "assure"  low levels (not absence) of L.mono in a given lot of finished product.

 

(3) Regarding vacpac (Post 1), if this is chilled, it falls into a FSA/C.botulinum control Regulation, declared short shelf life being one option.

 

(4) Regarding Sushi Grade (Post 5) I guess some consumers regard the claimed organoleptic benefits to justify an "internal"  bet. Just like oysters.


Kind Regards,

 

Charles.C


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#12 DRFSM

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Posted 30 April 2018 - 07:50 AM

Hi DRFSM,

 

I don't think you can guarantee listeria free 100% with no kill step (I don't personally think you can 'guarantee' food safety in any real sense) - but rather ensuring the risk and bacterial load ...if present....is as low as you can make it.

Regulations require ND yes ....and your hurdles should make this achievable seeing as you wouldn't test every single product from every batch.

 

We use positive release on the other end....completed product......we are not able to positive release on incoming RM as it is our farmed product.....no way to reject (read....not allowed....haha).

And our testing has shown that we do bring in l.mono on the fish (seeing as it is environmental this is no surprise) but in very small amounts and always under ~3 cfu/g - when we see it in larger loads it generally means contamination post harvest.

Seeing as it is bought in in small amounts....the hurdles are set up to A) ensure no further contamination from processing etc and B) to ensure that the small amounts that MAY be present are not given the chance to out compete other natural flora (whole fish gutted and cleaned well with potable water that is 'spiked' to increase chlorine to approx 3ppm. Fillets go under a spray bar after they come off the frame (potable water) and then the product sits in a chilled environment (under 5c) until ready to process into Grav.

The grav mixture is the next big hurdle - salt, sugar, alcohol, etc to attain a WPS of ~3.5% - the product is then placed on hold for testing. We are generally getting TPC of between 100 and 500 cfu at start (higher than cold smoked) and find mono about twice per year (process grav twice per weeek .....so give or take....2% of the time).  Let me know if this helps at all .... there are also some things you can do with batch testing to ensure you are not looking at dumping large amounts of product.....WIP vs finished goods scenarios.....and potential for hot smoking so then you can use in further byproduct etc....

 

Very useful information, FAO Charles.C im talking UK regs / location. as far as im aware Listeria is not detected requirement.

So i guess positive release is the only way to ensure food safety however. 3.5% WPS (water phase salt content) would only help to control the growth of C.bot in vac pack formats. this would have nothing to do with controlling Listeria AFAIK as Listeria will happily grow in higher salt contents and a wide range of low temperatures within chilled and frozen margins.  What kind of shelf life are you obtaining on product to be able to test for Listeria prior to release?  testing takes my lab nearly a week.....which is a long time to hold a product with short shelf life...

 

Yes short shelf life is a control of VAP Pack products <10 days if no controls in place but if you have: WPS% 3.5, AW <0.97 and some others you can use that to justify (all other things being ok) a longer than 10 day shelf life. but again this is for C.bot not Listeria...

 

I see that Ben uses a chlorine wash, i have never used this in any previous role so im  unfamiliar with it and how it is formualted  (Concentrations, what type of  chlorine used) and would control if at all Listeria??? 



#13 Quality Ben

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Posted 30 April 2018 - 08:01 AM

Hi - I have tried to answer some of these best I can but I am not in UK either so regs a bit different here.

 

Very useful information, FAO Charles.C im talking UK regs / location. as far as im aware Listeria is not detected requirement.

So i guess positive release is the only way to ensure food safety however. 3.5% WPS (water phase salt content) would only help to control the growth of C.bot in vac pack formats. this would have nothing to do with controlling Listeria AFAIK as Listeria will happily grow in higher salt contents and a wide range of low temperatures within chilled and frozen margins.  What kind of shelf life are you obtaining on product to be able to test for Listeria prior to release? Shelf life of 35 days vac packed. testing takes my lab nearly a week.....which is a long time to hold a product with short shelf life...our lab is using maldi-tof which means we can have an ND or a presumptive within two days - this helps a lot but we were also using this positive release method when with our older lab which took almost a week using older style methods. 

 

Yes short shelf life is a control of VAP Pack products <10 days if no controls in place but if you have: WPS% 3.5, AW <0.97 and some others you can use that to justify (all other things being ok) a longer than 10 day shelf life. but again this is for C.bot not Listeria...

 

I see that Ben uses a chlorine wash, i have never used this in any previous role so im  unfamiliar with it and how it is formualted  (Concentrations, what type of  chlorine used) and would control if at all Listeria??? Not chlorine wash per say.....and not to control listeria....remember it's all about hurdles. A lot of water is used while processing the fish and we just up the chlorine a bit - potable water is between 0.5 - 5ppm chlorine....we still sit inside that but we ensure it sits higher rather than lower.

 

 

Hi DRFSM,

 

A few more comments -

 

(1) I'm not sure as to the consumer location of the product discussed in OP (UK?)  but, apropos Q.Bens input, I noticed this comment in  attached FSANZ document (undated,ca 2013) -

 

attachicon.gif Guidance on the application of L.mono, micro. criteria, in RTE food.pdf

(also see -

http://www.foodstand...-eat-foods.aspx

 

UK may have a different Regulatory viewpoint of course (= EC? = ?)

 

(2) If a ND criterion does apply then I guess the sampling situation becomes analogous to Salmonella detection in Foods. Very high sampling levels (much greater than the typical Regulatory levels)/negative results will be required to statistically "assure"  low levels (not absence) of L.mono in a given lot of finished product. We do sample higher rates to 'assure' lack of mono

 

(3) Regarding vacpac (Post 1), if this is chilled, it falls into a FSA/C.botulinum control Regulation, declared short shelf life being one option.

 

(4) Regarding Sushi Grade (Post 5) I guess some consumers regard the claimed organoleptic benefits to justify an "internal"  bet. Just like oysters.

 

Overall what we do is ensure our hurdles and controls are as robust as they can be, ensure testing is comprehensive and actively 'searches' for listeria rather than ticks the testing box, positive release.



#14 Charles.C

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Posted 30 April 2018 - 05:08 PM

Hi DRFSM,

 

I am unsure that you are generally correct regarding a Regulatory zero tolerance for LM in UK/RTE Chilled Foods. I attach a couple of related UK documents.

 

Attached File  Shelf life of RTE foods in relation to L.monocytogenes.pdf   751.8KB   20 downloads

Attached File  HPA, 2009, RTE micro. guidelines.pdf   998.98KB   23 downloads

 

I appreciate Q.Ben's comments on inability to control growth of LM with respect to aw  however I attach one document demonstrating such a feasibility and the resulting options for increased shelf life. Not my area so no idea if the contents are operationally unrealistic**.

 

Attached File  Shelf life of Gravlax Salmon,2017.pdf   604.5KB   25 downloads

 

** indeed the aw data in this Icelandic survey tends to support Q.Ben's opinion -

 

Attached File  L.mono levels in Cold smoked Salmon and Gravlax,2000.pdf   156.4KB   12 downloads


Kind Regards,

 

Charles.C


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#15 DRFSM

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Posted 10 May 2018 - 10:54 AM

Hi guys thank you so much for all your help with this issue.

I have read and re-read all the above posts and documents and its very useful and has helped me a lot...

 

From my understanding or interpretation some countries have a zero tolerance in 25g sample of listeria in RTE products and some countries are using a zero tolerance in some RTE products i.e those intended for vulnerable groups or at high risk groups and an acceptable detection of listeria <100cfu/g in RTE products not intended for vulnerable groups.

 

Also i have seen many documents on listeria, most of which talk about PH, Aw levels and WPS levels INHIBITING the growth of Listeria... In this context im coming to the conclusion that providing that the levels stay below 100 cfu/g during shelf life the product would be passable.

 

However the one document i feel really helps is the :Shelf life of RTE foods in relation to L.monocytogenes ABOVE . a joint document by members such as Bakafrost Tesco BRC, CFA, and most importantly to me the FSA states in a paragraph the following:

 

Foods are not considered to support the growth of L. monocytogenes if:  
 
• pH is less than or equal to 4.4, or  • aw is less than or equal to 0.92, or  • pH is less than or equal to 5.0 with the aw being less than or equal to 0.94 
 
If these parameters are used to demonstrate that the food will not support the growth of L. monocytogenes then  
 
• these are critical control points and must be monitored as part of HACCP, and • further shelf life studies are not required in relation to L. monocytogenes

 

 

so by my understanding using this document as a reference provided my  aw and PH meets the above requirement then the product would be fit for the consumer with a presence of listeria < 100 cfu/g provided it does not exceed this by end of shelf life.

The process for PH and aw control would be CCP's during my process provided that listeria is within tolerance at the end (validation required obviously) and i definitely can see positive release being the way forward for this product range.

 

Any thoughts?



#16 tdunkley

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Posted 17 May 2018 - 03:02 PM

Wondering how aqueous phase salt / water phase salt correlates to the finished product sodium content on the NFT for this type of product. Any suggestions? Is there a standardized calculation that can be used (i.e.: 3.5% WPS = x on the NFT)?

Regards,

Theresa






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