16 replies to this topic

[sarahqa]

Hello, I am working on a HACCP and HARPC (FSMA) plan for our process of cooking soup to over 165F, hot filling into bottles at over 165F, and chilling in bottles. They are then stored refrigerated. I was originally thinking the hot filling step was just a control point, but since it is the same minimum temperature as our cooking step, I am starting to think that cooking would not be our CCP and hot filling would. Does anyone have any insight as to how to distinguish this? Or what people have done in similar operations?

[Scampi]

The fill temp should be your CCP.........but I would caution you to increase that temperature to at least 185 to account for cooling during filling and to assist with the death of spoilage organisms

 

I would add cook temp as a CP (control point) that is still monitored............but not "critical"

[sarahqa]

Thanks, Scampi. That helps clear it up. This isn't the first time I have seen mention of much higher filling temperatures. Is there a guideline that "at least 185" comes from? Or is it just due to estimated cooling during filling? From what I understand, 165 should be sufficient to kill what I am concerned about, but I can see that there should be some built in buffer to account for the time between filling and sealing/capping.

[Brendan Triplett]

Sarah,

 

My thought would be that if the step is being used to control pathogen growth from the bottles and keep the product "clean" that you could make an argument for it to be a CCP.  I have heard of it being done to help ensure good seal on the bottle during final packaging but I do not know how it is incorporated into the plan.  I guess if it is set up to prevent growth then yes but if it is set up is for getting a good seal then maybe not.

 

HACCP says this - Identifying the critical control points at the step or steps at which control is essential to prevent or eliminate a hazard or to reduce it to acceptable levels;

 

Could you argue that this step does not eliminate hazards from the bottle?

 

Maybe Scampi has different experience on it.

[Scampi]

Most yeast/mold need at least 160-----------so 165 doesn't give you a very good margin of error--------------what sort of shelf life are you after?

 

https://foodsafety.w...osing a Hot.pdf

 

But this chart is scientifically validated for products with a ph of 4.1 or less that are shelf stable

 

what is your pH?

 

According to UN-L the REHEAT temperature for soup is 165F

 

There are some heat resistant strains of e coli out there.........so in order to produce a safe product, aim high

 

https://www.ctvnews....shows-1.2929942

[Scampi]

Sarah, are you in production already?

[kfromNE]

Don't forget about your hold time at 165. We hot fill items as well. When audited, how long we held our product at our CCP temperature was just as important to them. So our CCP is the temperature and time our product is heated to.

[012117]

Sarahqa,

 

Same with KfromIA, how do you validate this as CCP espcially during peak season that you may want to increase your production rate? As always for kill step, it is always combination of temp and time.  From my point of view, pasteurization can be the CCP and hot fill to prolong shelf life of the product.

 

Hi, Brendan.

 

She may have referred to it on ISO to the question "is there subsequent step" and thought of hot fill as the subsequent step to eliminate/reduce to acceptable level the identified hazard.

[gud2ya]

hot filling is your kill step since you have no other step after it that would reduce or eliminate microbial hazards (based on decision tree)

[sarahqa]

Ah, seems like the differences in opinion here are also what is confusing me. From a FSMA standpoint, it is easier - they are both process preventive controls. But I am considering the "is there a subsequent step" in the decision tree to mean that hot fill should be the CCP. Also, the cooking step is not specifically designed to eliminate/reduce hazards - the product needs to be cooked to become soup. The cooking temperature requirement is designed for eliminating/reducing hazards, though.

 

The product is not acidic. I have not specified a hold time; I was thinking as long as the product temp reached 165 that is a sufficient kill step - based on most time/temp tables for vegetative pathogens, a temp as high as 165 is not tied to a length of time.

[Charles.C]

Perhaps also see this thread for some more context -

 

https://www.ifsqn.co...ert-validation/

[Scampi]

Sorry Sarah but hold time IS important.

 

Let's say you've got vegetative cells that are heat resistant to 164F but die at 165, but they require 2 minutes for a 5 log reduction.............

 

 

There is reams and reams of data/research out there about specific hold times for specific pathogens and spoilage organisms.

 

Even for products will a pH of 3.8 for example the hold time is still 1.2 minutes at a fill temperature of 160F and that's including all the other hurdles naturally occurring in acidified foods (salt, acid, sugar etc)

 

I know you are refrigerating your product and that helps significantly but the purpose of hot filling (beyond product integrity) is to sterilize the container and you cannot do that without an appropriate hold time

[Fishlady]

I would suggest that you contact a process authority to validate your control measures.

[bhanson]

Sarah, per the previous post, your fill time and temperature are your critical control point.  We are also a hot-fill production facility, and have a second critical control point following the hot filling.  The FDA requires a drop from your hot-fill temperature to below 70 F to occur in two hours.  The remaining cooling from 70 to 38 degrees can occur over a four-hour time span.  Something you may want to consider as an additional control.

[tkloch@ford]

Time and temperature would both be CCP. In addition I agree with bhanson on the drop temperature as well. I would think would be just as important.  Do you use chart recorders in your facility?  

[kfromNE]

https://foodsafety.w...lProcessing.pdf

 

 

If it has a pH between 4.1 to 4.6 - this article would work.

[Gerard H.]

Dear Sarah,

 

Just a few remarks, that I would like to add to be sure you will get the best results:

• If not done yet, identify the micro-organisms and eventual spoiling enzymes you are targeting. Because for each species there are D values (Time-Temperature combinations) available (indeed, maybe you will have to buy this information from a competent authority). It allows you to know whether all the targeted organisms are killed or that certain spoiling enzymes are inactivated
• The temperature after filling can be measured inside the bottles by temperature loggers. This gives you more insight in what happens during and after filling
• The above approach prevents you from overheating your product, which isn't good for the organoleptic aspects
• Having the insight about when and where the micro-organisms are killed and the spoiling enzymes inactivated, the HACCP decision tree tells you the rest

I wish you good luck with the development of this new process.

 

Kind regards,

 

Gerard Heerkens