9 replies to this topic

[MaarjaS]

Hello,

 

We are producing frozen fruit and vegetable sachets, so the product comes in frozen, stays frozen during the production, is then stored frozen and consumed.

 

We are looking to add ice cream pellets with our frozen fruit, so again - mix of fruit and ice cream. product is frozen throughout the production and storage; end product is blended and consumed frozen.

 

I believe that it is low risk, but after the BRC conversion course I had yesterday I was told it is high risk.

 

I am referring to Appendix 2 on version  8

 

Any advice is much appreciated

 

thanks

[Scampi]

YOU are blending the ice cream with the fruit???  Or is the consumer??  It's not clear from your post

[MaarjaS]

sorry, ice cream is already with the fruit.

 

consumer opens the sachet with fruit and ice cream and blends it with milk.

[Scampi]

Ok, since you are adding DAIRY to the facility and dairy (regardless of is state) has a lot of extra worries, you would be considered high risk. 

 

 

https://www.eater.co...recall-listeria

 

According to the University of Guelph, these are the pathogens of concern in dairy (of all kinds)

The following bacterial pathogens are still of concern today in raw milk and other dairy products:

• Bacillus cereus.
• Listeria monocytogenes.
• Yersinia enterocolitica.
• Salmonella spp.
• Escherichia coli O157:H7.
• Campylobacter jejuni.

Add that to the listeria that could be on the frozen fruit/veg and you've got to increase the sanitation and swabbing game

[pHruit]

I can't see how that would fit into the low risk classification?

The options for low risk seem to be:

• Cooked by the consumer - doesn't apply
• Processed within final container - doesn't apply
• Unsuitable for growth/survival of pathogens and stored as ambient products - doesn't apply
• RTE product that are chilled/frozen for quality only, with other controls for pathogen growth - doesn't apply
• raw materials prior to undergoing a kill step for entry into high risk/care - doesn't apply.

Are all of the components you're using cooked/pasteurised? If not then it doesn't appear that it fits into high risk either, as one of the necessary criteria is that all components have received a "full cook" . if you're using fruit purees or similar then these may not necessarily meet the definition even if pasteurised, as this would often be based on a 5-log validation rather than the 6-log requirements in footnote 1 in BRC appendix 2.

Dependent upon the status of your individual ingredients you may therefore actually fall into the High Care category.

 

I'm a bit wary of some of the BRC8 conversion courses at present - sent a member of my team to one recently and was not at all impressed by the feedback. Sort of wonder if the trainers have had time to properly familiarise themselves with the new standard before these first few courses...

 

@Scampi - BRC includes its own specific definition of low risk / high risk / high care. Under this classification, some dairy products could actually be considered low risk (e.g. certain types of cheese)

[Scampi]

thanks pHruit

 

I was thinking specifically of the Blue Bell ice cream recall (that went on and on).........listeria was introduced to the plant from an ice cream ingredient and sickened many people and reappeared in the ice cream ~6 months later

[MaarjaS]

Hello, thank you for your comments.

I am aware of the micro risk in ice cream and dairy product, however before ice cream arrives to our site it is pasteurised and frozen at our suppliers site, it would also be positive released.

 

so If I look page 93 on BRC, still part of the appendix 2

 

Are the final product stored ambient, chilled of frozen?

frozen

are products or ingredients within the area open to the environment?

yes

does the product support the growth of pathogens or the survival of pathogens, which could subsequently grow during the normal storage or use of the product unless stored chilled or frozen?

yes/no? I think it is no, as product is already been heat-treated at source and will remain frozen until end of its shelf life. the normal storage would be frozen?

also 95% of our production is frozen fruit and vegetable what will definitely go on this category according to BRC.

 

And also if we do go under high risk for this product, any ideas how I can manage it, we are such a small site to change the whole layout would be almost impossible.

 

All we do is open the bag in box, decant it to plastic container, lift it up to multiweigh to mix the ice cream pellets with some frozen fruit and pack.

 

Any advice is hugely appreciated

 

thanks

[Charles.C]

Hello,

 

We are producing frozen fruit and vegetable sachets, so the product comes in frozen, stays frozen during the production, is then stored frozen and consumed.

 

We are looking to add ice cream pellets with our frozen fruit, so again - mix of fruit and ice cream. product is frozen throughout the production and storage; end product is blended and consumed frozen.

 

I believe that it is low risk, but after the BRC conversion course I had yesterday I was told it is high risk.

 

I am referring to Appendix 2 on version  8

 

Any advice is much appreciated

 

thanks

 

Hi Maarjas,

 

How does BRC8 define high/low risk products ?.As per post 5 ?

 

This is not necessarily the same as identifying a process stage as X-risk.

 

Some texts define any RTE product as High Risk.

 

BRC have previously issued a detailed compilation of what they regard as "high" and "low" risk finished products. (Posted on this forum many times. offhand I don't remember if it included ice-cream).

 

In the general haccp literature I think you can find ice-cream evaluated as both high, low risk.

 

However if you are intending to be audited to BRC, their (documented) opinion is presumably "gospel" unless self-contradicted.

 

PS - as Scampi noted, the specific hazard is also relevant. I recall BRC are usually fixated on L.mono.

[pHruit]

Hi MarjaaS,

Interestingly the low risk examples on p90 are provided as "include the following..." rather than the "must meet..." criteria given for high risk / high care / ambient high care.

(Charles - my post summarises what is in the standard with regard to low risk, but it's designed to be used in conjunction with the decision tree mentioned in post #7 and several pages of text. One could almost state that that low risk is a default position if you've ruled yourself out of both high risk and high care by defining what it isn't, rather than there being a specific definition of what is low risk).

 

It is somewhat unfortunate that there is a degree ambiguity around wording of decision tree step 3 - IMO there are at least two ways that it could be read, one of which leads to the conclusion you've reached, but the other would be that if there is potential for pathogen growth outside of chilled/frozen storage then the answer would be "yes" rather than "no".

The closest thing I can readily see to a definition of the point in question is in the 4th bullet point of the "high risk" blurb / 3rd bullet point in the high care blurb - these refer to frozen then defrosted, risk from not being immediately consumed etc. Under this criteria you'd have a very reasonable argument that  "no" is indeed the correct choice for decision tree step three, as whilst the ice cream would support pathogen growth it certainly shouldn't do so under normal use.

Apologies if this seems to contradict my earlier post. I think you sit in a slightly unusual area of the standard for this particular case!

Have you tried asking the same question via Participate?

As I mentioned above, my faith in the conversion courses is rather limited currently so I'd try approaching BRC this way I think.

You could also try enquiring with the Ice Cream Alliance as the UK's trade body for the sector, as they'll almost certainly have already considered it as an industry group.

[MaarjaS]

 

 

Hi MarjaaS,

Interestingly the low risk examples on p90 are provided as "include the following..." rather than the "must meet..." criteria given for high risk / high care / ambient high care.

(Charles - my post summarises what is in the standard with regard to low risk, but it's designed to be used in conjunction with the decision tree mentioned in post #7 and several pages of text. One could almost state that that low risk is a default position if you've ruled yourself out of both high risk and high care by defining what it isn't, rather than there being a specific definition of what is low risk).

 

It is somewhat unfortunate that there is a degree ambiguity around wording of decision tree step 3 - IMO there are at least two ways that it could be read, one of which leads to the conclusion you've reached, but the other would be that if there is potential for pathogen growth outside of chilled/frozen storage then the answer would be "yes" rather than "no".

The closest thing I can readily see to a definition of the point in question is in the 4th bullet point of the "high risk" blurb / 3rd bullet point in the high care blurb - these refer to frozen then defrosted, risk from not being immediately consumed etc. Under this criteria you'd have a very reasonable argument that  "no" is indeed the correct choice for decision tree step three, as whilst the ice cream would support pathogen growth it certainly shouldn't do so under normal use.

Apologies if this seems to contradict my earlier post. I think you sit in a slightly unusual area of the standard for this particular case!

Have you tried asking the same question via Participate?

As I mentioned above, my faith in the conversion courses is rather limited currently so I'd try approaching BRC this way I think.

You could also try enquiring with the Ice Cream Alliance as the UK's trade body for the sector, as they'll almost certainly have already considered it as an industry group.

 

thank you for this, your comments are very much appreciated. I just want to be confident and have no doubt that we are complying with this section of BRC standard (well I was until I was told that I'm completely wrong). I've also found that it states under Low Risk description: do not support the growth of pathogens or the survival of pathogens, which could subsequently grow during the normal storage or use of the product.