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Nikki R

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Posted 20 October 2018 - 10:36 AM

Hi all,

 

My head hurts and I need help! Is there any legislation which states how fast food needs to be cooled down. We have a product which is quite thick and is over 100 degrees celcius when it come from the kettle and it is blast chilled overnight before the next production stage. An auditor told us a few years back it needs to be down to temperature within 90 mins so we splashed out a lot of money for a blast chiller that we were promised would do the job. The company failed and the quickest time they could achieve was 4 hours to cool below 8. We have approached several companies who can not do it in the 90 minuites either. The prodcut can not be frozen as it causes quality issues. I have searched the internet high and low but I can not find any solid leglislation with maximum time ranges. Does this exist? The closest I can find is "As fast as possible" 

 

I have read a thread on this site from 2010 where someone stated that cooling should not exceed 6 hours and product should be down to 21 degrees celcius in the first 2 hours and less than 5 degrees in the next 5 hours. the link in his comment does not work so I cant determine if this is fact or old information etc. 

 

I have read somewhere that a scientific risk assessment can be used to cover products that fall out of the temperature ranges but wanted to make sure we are not breaking the law if we take this approach. It is looking more and more like we will not be able to produce this product.

 

Can any of you provide links or pint me in the right direction. I have read so many EU regulations that I could cry  :shutup:



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Posted 22 October 2018 - 07:01 AM

Hi, Nikki.

 

Not so sure if this is what you need. There is some EN number I forgot but I'll input once I remember :)

 

http://www.foodstand...okingf1479.aspx

 

https://www.fsai.ie/...re_control.html

 

http://www.foodstand...trolma1477.aspx

 

http://www.legislati.../1995/2200/made referring when lowered to 63C and POS for 2 hours, but I assumed, this is not related to your goods.

 

https://assets.publi...es_Amnd_010.pdf



3560lynne

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Posted 22 October 2018 - 10:41 AM

What is the product?

 

This USDA information may be helpful:

 

FSIS Appendix B (Stabilization Guidelines) - 1999

 

June 2017 Compliance Guidelines for Cooling (Revised Stabilization Guidelines)

 

Askfsis: Part 2 of 2: Recommendations for establishments that cannot meet the 2017 stabilization guidelines revised Appendix B - you'll find a chart with options in their answer and after the chart you'll find the following "Establishments that are not able to meet one of the extended options may consider using the following as scientific support; FDA's Food Code, Section 3-501.14 Cooling, CFIA cooling procedure found in the Cooling of Heat Processed Meat Products...



trubertq

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Posted 22 October 2018 - 10:56 AM

Attached, Guidance Note 20 from FSAI, its a good place to start. 

Attached Files

  • Attached File  gn20.pdf   515.94KB   78 downloads

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3560lynne

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Posted 22 October 2018 - 11:01 AM

It just occurred to me - your auditor saying you have 90 minutes to chill the product - there must be some misunderstanding. 

 

From the guidelines - Chilling should begin within 90 minutes after the cooking cycle is completed.

 

Not be completed within 90 minutes. 



Charles.C

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Posted 23 October 2018 - 02:58 AM

Hi Nikki,

 

I recall this has been discussed for UK before here. Possibly at the thread you mentioned in yr Post. Can you post that link ?

 

The specifics may relate to what you meant by  "quite thick " ? .1inch is not the same as 1foot.

 

I think the "global"  conclusion for very "large" (and misshapen) objects was that countries vary in opinion..

 

Trubertq's attachment has an excellent review / practical results of Campden UK. One slight caveat is that the ref.  is quite old (ca 2000) however I doubt that the basic concepts have materially changed. (There is a chunk of the reference in the older thread here).

 

I noted that EC have no specific time/temp guidelines (ca 2005).

Legislation  specific  to  heating  and  chilling  of  foods  exists,  but  is  largely  unstandardised
throughout  the  European  Union  (EU).  Foods  typically  receive  heating  and  chilling  based
on  agreed  best  practice,  national  standards  or  guidelines.

 

 

IIRC Australia separate taget times/temps based on "size" for large objects.

 

PS - basic theory quoted was -

 

12.  At  a  minimum,  chilling  should  prevent  or  reduce  the  opportunity  for  any  surviving
spores of Clostridium perfringens, Cl. botulinum and Bacillus cereus to germinate and grow
in the food following heat processing. As such, chilling should decrease the temperature
of  a  heat  processed  food  as  described  in  Section  3.0  of  this  document.

 


Kind Regards,

 

Charles.C


pHruit

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Posted 23 October 2018 - 08:58 AM

As Charles observed, the regulatory position in the EU as a whole isn't particularly specific, indeed it's perhaps wonderfully vague - Annex II Chapter IX of 852/2004:

6. Where foodstuffs are to be held or served at chilled temperatures they are to be cooled as quickly as possible following the heat-processing stage, or final preparation stage if no heat process is applied, to a temperature which does not result in a risk to health.

 

 

A great deal of the UK guidance is focussed on foodservice/catering, but it could be useful to note that this talks about cooling in the "danger zone" (cue Top Gun music) which it considered to be between 63°C and 8°C. As you're starting with temps ≥100°C, some of your cooling time is spent outside of this so if you've got the monitoring data to support it then this may help presentation to auditors who've possibly slightly misunderstood or are a little misguided.

For your own purposes you'll still need to consider full implications, nature of product etc, but given that you're apparently able to get from 100°C-8°C in four hours from point of cooking, it seems quite possible that you'd be very close to meeting the best-practice guidance in trubertq's very useful link - 90 mins + 120 mins gives you 3.5 hours to get from cooking temp to 10C.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 



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Posted 23 October 2018 - 12:40 PM

Below you will find CFIA poultry chilling requirements..........perhaps if you use these VALIDATED time/temperature in your program it will satisfy your auditor!

 

 

http://www.inspectio...62607138?chap=8


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Charles.C

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Posted 23 October 2018 - 07:20 PM

Below you will find CFIA poultry chilling requirements..........perhaps if you use these VALIDATED time/temperature in your program it will satisfy your auditor!

 

http://www.inspectio...62607138?chap=8

 

Hi Scampi,

 

Ahem.

 

The link seems mainly about water chilling (an admittedly probably superior methodology to air).

 

I could not find any validatory information except this intriguing comment -

The chilling process results in chilled product which complies with the Pathogen Reduction Program requirements as contained within the section on the US in Chapter 11, Exports, of the MOP.

 

I also noticed this curious statement for air-chilling -

 

Unlike water chilling, there are no time requirements to meet the internal temperature of 4°C or lower as long as the chilling process is continuous and air chill room temperature is maintained at 4°C or lower.

Kind Regards,

 

Charles.C


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Posted 23 October 2018 - 07:27 PM

You are correct Charles, but even still, it is scientifically validated..........the new regs coming in January 2019 are even less helpful!!!

 

The pathogen reduction program is the incredibly involved salmonella and ecoli swabbing that must be done..........get 1 positive hit out of 52 sets (not days sets) and you have to implement corrective actions, you cannot export to the US and you have to repeat the entire set again!

 

 

You'll notice, however, the room temp needs to be 4C OR LESS........the second you are above 4 you are in deviation and would have to follow you're deviation procedures.........the air chill system I used had the birds frozen solid in under 4 hours..............so you still have to follow best practices

 

Most places ARE NOT air chilling poultry.........at least not in north america...........water chilling is much cheaper (plus you can prove you can reuse the water)

 

Water chilling IS NOT superior..........both have pros and cons...........think about it......birds bobbing around in a pool of recirculated water?  Um no thanks

19.8.4.1 Air Chilling Time Requirements

Unlike water chilling, there are no time requirements to meet the internal temperature of 4°C or lower as long as the chilling process is continuous and air chill room temperature is maintained at 4°C or lower.

However, the CFIA would not object if the chilling process is momentarily interrupted to either individually or bulk pack and/or tie carcasses as long as:

  • the product must have reached 10°C or less
  • the interruption must not result in temperature increase of the carcasses
  • the chilling protocol be validated to the satisfaction of the Veterinarian in Charge

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Charles.C

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Posted 23 October 2018 - 08:03 PM

 

You are correct Charles, but even still, it is scientifically validated..........the new regs coming in January 2019 are even less helpful!!!

 

The pathogen reduction program is the incredibly involved salmonella and ecoli swabbing that must be done..........get 1 positive hit out of 52 sets (not days sets) and you have to implement corrective actions, you cannot export to the US and you have to repeat the entire set again!

 

 

You'll notice, however, the room temp needs to be 4C OR LESS........the second you are above 4 you are in deviation and would have to follow you're deviation procedures.........the air chill system I used had the birds frozen solid in under 4 hours..............so you still have to follow best practices


 

 

Hi Scampi,

 

IMO the FDA quote is not a Validation, it's a Verification.

 

I was only (mentally) comparing freezing efficiency for the water/air systems from a (direct/indirect) contact POV, not aesthetic beauty.  :smile:

 

Have never seen a liquid based system for product freezing but I have also (happily) never been in a poultry slaughtering plant either. I thought the objects were already in bags before dangling/immersing  in the liquid from an overhead conveyor setup. :smile:


Kind Regards,

 

Charles.C


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Posted 23 October 2018 - 08:07 PM

I will not add a thing here Charles........in this case believe me, ignorance is bliss! :shutup:  :shutup:

 

You cannot water chill fresh product in a bag (not large poultry anyway) as soon as you seal it up....the heat will actually increase and the .............i will stop here for those with delicate constitutions LOLOLOL


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Nikki R

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Posted 24 October 2018 - 08:52 AM

So sorry I have not responded until now, my youngest monkey has had tonsilitis so I have been away from work. Thankyou for all the information, I will look through it later on today  :ejut:



Nikki R

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Posted 24 October 2018 - 12:33 PM

Thank you all, I have found the same as Charles in that there is nothing specific. I have however found that exceptions can be make if there is a scientic assessment in place proving that the food is safe so we are looking into this with out lab. HAs anyone else taken this route and was it accepted by external authorities and auditors?



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Posted 24 October 2018 - 12:45 PM

This may also be of assistance

 

https://www.fsis.usd...pdf?MOD=AJPERES

 

NOTE: The USDA/FDA, CFIA and the Austrailian food safety body entered into agreements that the 3 nations have equal food safety programs in place.....so I would think if you use the standards as prepared by one of those 3, that you should be able to satisfy any CB.

 

The above link speaks specifically to meat products RTE and NRTE

 

4 hours to below 8 has proven (validated) safe

Charles, if a government body posts cooling time/temperatures it is because those are VALIDATED scientifically to produce a safe finished product. So if any operations (while maintaining good GMPs et all) follow those time/temp regs the process really should not need VALIDATED within the facility


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3560lynne

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Posted 24 October 2018 - 04:03 PM

Scampi's link regarding USDA is what I referenced (it's what we use) and this may help - 

 

Establishments may choose to employ these guidelines as their process schedules. FSIS considers these guidelines, if followed precisely, to be validated process schedules, since they contain processing methods already accepted by the Agency as effective.



Charles.C

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Posted 25 October 2018 - 05:11 AM

Scampi's link regarding USDA is what I referenced (it's what we use) and this may help - 

 

Establishments may choose to employ these guidelines as their process schedules. FSIS considers these guidelines, if followed precisely, to be validated process schedules, since they contain processing methods already accepted by the Agency as effective.

 

Note that OP is in UK.

 

@ Scampi - I may agree with you after I have seen the Validation. Trust but Verify.

 

I have previously seen specific Australia Guidelines posted here but admittedly I think it was a quite old reference. Their "Spokesperson" is ANZFA who I think tend to well trust their own science, eg CSIRO, in general.

I like FSIS's classic Validation Text muchly however their micro beliefs as to the most relevant target organism can be (and have been) contentious.

 

@Nikki - you should maybe contact Campden. They may be happy to freely tell you whether anything has much changed from their pioneering work. Or propose you invest in an updated Guidelines.


Kind Regards,

 

Charles.C




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