24 replies to this topic

[emilya76]

Our cooler went down that was storing ricotta cheese, shredded cheese and eggs.  The product reach 44*F within 6 hours, though how long it was held here is unknown.  All of these products have a kill step (they are made for making pasta) and will be boiled in water.  Would these be safe to use or considered garbage?  I have been searching the internet for an hour and am finding conflicting reports.  Thank you!

 

 

Emily

[jcieslowski]

Is maintaining product temperature a CCP or at least a control point for you?  If so, what does the procedure say you do?

 

Since you do not know how long it exceeded safe temperatures, you must assume it was a 'worse case scenario' and has all gone bad and should be thrown out.  

[emilya76]

We do not have it as a CCP only because we have cooking as a kill step. 

[emilya76]

Thank you!

[Scampi]

I would run micro on your ingredients........6.6C would be ok if you knew how long the cooler was like that

 

Is your kill step validated for this scenario?????

[jcieslowski]

I'm personally skeptical of the kill steps ability to eliminate the threat if there were toxin producing bacteria present, for example.

 

If we're talking a lot of money, then I guess you could do a micro test on your product to check it out but I'd feel safer personally with the 'when in doubt, throw it out' mantra.

[SQFconsultant]

When in doubt, throw it out.

 

You have no idea how long you have been out of proper temperature - this would be a hard one to explain to a regulatory agent if it came to that as to why you decided to use the product... Oh, well, no we don't know how long it was out of temperature - that will not fly.

[Sweet'n'low]

When in doubt, throw it out.

 

You have no idea how long you have been out of proper temperature - this would be a hard one to explain to a regulatory agent if it came to that as to why you decided to use the product... Oh, well, no we don't know how long it was out of temperature - that will not fly.

 

Couldn't have said it better myself, and a great way of putting it in perspective. 

Another way of looking at it, after that dairy has been left at that temperature would you eat it knowing it may be unsafe? If not, then why continue using it for others to consume. 

[Scampi]

We also have to remember that in all likely hood all of the raw materials have arrived AFTER pasteurization and I'm assuming (yes yes I know) that they are in the original containers

 

I would be sending out for micro before I  decided

 

BUT i would also be installing an alarm system and data loggers so if this happened again I'd have more information to work with

[Brendan Triplett]

Emily,

 

I would have to agree with most everyone on this forum.  We hold dairy and cheeses at temperature, though not as a CCP.  When we are checked by the FDA or any other regulatory group they review our temperature logs and ask questions about anything that gets out of temp.  If you keep the product and someone calls, or if god forbid someone gets sick and a committee starts to dig then you could really be in some hot water.  The product made it out of temp, you know that for sure.  If the product was out of temp for at least 2 hours (from your best guess) then you should take the safe route and trash it.  Guessing is what gets people in trouble and guessing, just to keep the product on the shelf, is a regulatory issue.  Trash it and start looking up ways to ensure temperature controls and possibly remote temperature monitoring so that you can have a better record in the future.  This sounds like a hard learning opportunity.

 

Cheers

[012117]

From my point of view, yes it was pasteurized but it not necessarily mean that the product is sterile. Considering as well the nature of the products affected, the product may likely support microbial growth during storage especially if the temperature requirement is not followed (on this case, for "how long" is not known thus it increases the uncertainty).

 

The product is also packed how? vacuum packed? On your HACCP study or your quality plan? What is says about your storage temp? The product may also be high risk with spore formers and boiling may not be sufficient on this case.

 

How many is affected? Initially, taking that you have identified properly the hottest area for your temp monitoring, I would recommend to scrap.

[bryan63]

With all of th food contaminate issues over the last few years, I don't know why saving this, relying on a "kill" process would even be considered... we are talking about throwing out a few hundred or even thousands of dollars over potentially making people sick or worse?  Come on... I find this disgraceful...  I used to train production personnel and I would always ask them, "whatever you do, would you give the result of your actions to your family, your kids to take, eat?"

 

Shame trying to "save" something is even being considered...

 

 

[RoundEggs]

I would run micro on your ingredients........6.6C would be ok if you knew how long the cooler was like that

 

Is your kill step validated for this scenario?????

I agree with the first line. You have no idea at all? No ball park even? Do you know when it went in the cooler and when the last time was that the temperature was checked?

 

I would do micro before making any decisions.

 

And as Scampi said put a Chart Recorder on the cooler at the very least and invest in an alarm.

[Charles.C]

Hi emily,

 

IIRC FDA have published time/temperature food guidelines for use in the event of home refrigerator failures.

 

A well-known guideline, particularly ex Australia, is the 2 hour/4-hour rule. variously discussed on this Forum,

 

However, if you cannot reliably estimate data so as to implement procedures such as the above, only the most conservative option seems applicable, ie reject.

[emilya76]

Bryan63,
Shame on you for talking down to a question. Is this not a place to learn and ask questions? I find your response completely disgraceful and out of taste for this forum. We had an ODA inspection today who after looking over the data loggers determined the product safe after comparing the product to the table in the fish and fishery book. (If you want the report I will gladly send it to you). Thank you for all the responses. We are getting the products micro tested for our own knowledge and is not required. No thanks to Bryan who clearly has no class when it comes to helping people.

Thanks everyone!
Em

[sqflady]

Emily,

I am glad you found a solution and were able to use the items.  Because no one else pointed it out, I wanted to add that FDA/USDA regulations allow shell eggs and standard of identity dairy products to be held at 45* degrees or lower. 

[Scampi]

I think we are in an environment that causes people to lose their heads from time to time, but I come from a heavily regulated background and know about what I speak.

 

Yes, we all have an obligation to ensure we are producing safe whole some food............but that doesn't always mean scraping items as a first response. Common sense should be what is used (and it's not alot of the time) supported by sound scientific analysis. After all, each and everyday our jobs are boiled down to microbiology and chemistry

 

I have spent the last 6 months at this post (seriously 6 months) reviewing, not only old processing logs but speaking directly with industry experts to make sure not only are we producing safe wholesome food each and every time, but I am ALSO being financially responsible. 

Regardless of if said companies fails due to a recall or to over spending on items WITHOUT value, I am still without a job at the end of the day. 

 

My #1 priority at work is safe wholesome foods, but making knee jerk reactions that are not based on fact will land me jobless, I do not care for whom you work or what you do, one too many bad decisions and you will find yourself job hunting.

 

Decisions made by knee jerk reactions OR not based on science is what causes people to become ill from the food they eat.

 

I have had to go to my boss or owner and tell them to dump product, and I am not afraid to do that, but it is also my job to prevent that from having to happen

[RoundEggs]

With all of th food contaminate issues over the last few years, I don't know why saving this, relying on a "kill" process would even be considered... we are talking about throwing out a few hundred or even thousands of dollars over potentially making people sick or worse?  Come on... I find this disgraceful...  I used to train production personnel and I would always ask them, "whatever you do, would you give the result of your actions to your family, your kids to take, eat?"

 

Shame trying to "save" something is even being considered...

 

The goal is to be supplying quality-food safe ingredients/products - however another goal is to ensure the reputation of the company and maintain current customers. If you don't have a profitable business-then you don't have a job.

There is nothing wrong with considering that the customer may be using a kill step on your supplied ingredients. That is a  control to a possible hazard. 

 

If it was a different scenario and the time was known then considering a kill step by the customer might be a viable solution. 

 

I have been involved in a recall situation and government inspectors absolutely take into account when assessing risk if there is a kill step involved by the customer ( as a means of a control on an otherwise potentially unsafe for consumption product) - so I do not see anything wrong with the company themselves taking this into consideration. 

Edited by RoundEggs, 28 September 2018 - 03:23 PM.

[Scampi]

I would also like to say to bryan63--------not once was it suggested that anyone look the other way and "save" the product in question blindly. 

 

Emily---------please do let us know how this filtered out and have you demanded better controls on the coolers?

[bakeryscience]

Bryan63,
Shame on you for talking down to a question. Is this not a place to learn and ask questions? 

 

Yes!! You are so right. I have to admit, sometimes I'm scared to ask questions on here because I don't want a reaction like this! I am new at this and learning day by day.

Edited by rebudke, 28 September 2018 - 03:49 PM.

[emilya76]

I would also like to say to bryan63--------not once was it suggested that anyone look the other way and "save" the product in question blindly. 

 

Emily---------please do let us know how this filtered out and have you demanded better controls on the coolers?

 Sorry let me add more detail.  The products were on pallets.  When temped only the top of the pallet was temped (worst case scenerio).  Temping the product on the bottom of the pallets it was still 36*F, still under 40*F and considered safe.  We do have an alarm system on the cooler and a cooler truck.  The reason the product was allowed to get up to 44*F was because we had to turn on the cooler truck (used in emergencies) and wait for the temp to come down.  The product on the top of the pallet has been sent out for mico just for our own piece of mind and validation. 

[Scampi]

Oh!!!!!!!!!!

 

That sort of thing happens all the time!  Refers do not drop in temp automatically (even though we wish they did)

 

Well then, best of luck and I'm sure your micro will come back well within your acceptable range!

[FSQA]

Emilya76,

 

I think most of us (mis)understood that the temps were out of range/went unrecorded for an ample period of time based on the info: The product reach 44*F within 6 hours, though how long it was held here is unknown.

Based on further info you provided in post # 21 above, it seems like the temps of the product got as high as 44*F (or in other terms it was kept <44*F during storage) which changes the prospective by a 180 degree.

 

Good Luck and hopefully the results will come out good.

[FurFarmandFork]

More options for you emilia:

 

You didn't share the details of the "testing" you wanted to perform, so we couldn't weigh in. Make sure they're meaningful and use an appropriate indicator organism that will demonstrate the impact of the higher temperatures, not just your finished good spec again.

 

If you're using quantitative results to determine the risk by the temp failure (as I assume you would), make sure you pull a statistically meaningful number of samples, not just 25g. I've got some references in this post to help you determine an appropriate number of samples for the level of confidence you're looking for. 

 

Speaking of organisms above, as you document your corrective actions/justifications for the product, include some data on minimum growth temperatures to identify which organisms would have been at risk of growing in your product, and you can check the risk of them surviving your pasteurization step vs. their ability to grow to limit the field of potential hazards in your assessment.

 

 

An additional reference, CDPH has a specified approach for potentially hazardous foods (foods requiring temp control) that has some more specific guidelines to cover more situations, I found it to be a more helpful approach than some of the other regulatory advice.

[Charles.C]

Hi 3F,

 

Nice CDPH(Californian) link. Expanded interpretation of 2-4hr rule.