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#1 cy2299

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Posted 31 October 2018 - 01:49 PM

There was a CCP temperature check record that was below the critical limit after a continuous conveyor cooking process. This CCP record also has a hold time record and a second temperature after the hold. The individual pieces are measured by instant read probe thermometers and are different pieces on the belt before and after the hold time. There are three temperatures taken at at each verification interval before and after the hold time. The critical limit at the first check was below the critical limit. The second check was also below the critical limit. The HACCP plan uses FSIS Appendix A Time-Temperature Tables for validation of the CCP. The first check was below the critical limit but the hold time exceeded the necessary lethality time for pathogen of concern. Since the second temperature after the hold time is below the critical limit, is it possible to use the first temperature to justify the CCP has been met because the second temperatures are all higher than the first temperatures? Does this prove that temperature increases and thus the lowest temperature recorded and hold time at first temp check could be used to verify the CCP?



#2 RennieSka

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Posted 31 October 2018 - 03:05 PM

Hi cy2299,

 

A few questions for you,

 

What does your HACCP plan specifically define as your CCP and what does it call for in the case of failure? 

 

Do you have any other validation studies (in-house or otherwise) to support the CCP you have set for your specific product? 

 

What type of product are we talking about? Is it the same type of product that the tables are intended for, or if not what was the justification for using them as validation?

 

We might need to know more about your product and process in order to better help you find an answer, but in my experience if your haccp plan defines CCP and you have not met that requirement, its likely no go. 



#3 Scampi

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Posted 31 October 2018 - 03:41 PM

I agree, you need to follow your own deviation procedures.............you could perhaps after this incident reevaluate your CCP and it's parameters, but since it appears your deviation does not state and "OR" it says "BOTH" then your product is out of compliance and needs to be reworked or destroyed

 

did BOTH sets of time/temperature meet any of the FSIS standards?

 

Your example will ONLY be sufficient if you've exceeded the FSIS minimum time AND temperatures.......those values work in conjunction

 

There was a CCP temperature check record that was below the critical limit after a continuous conveyor cooking process. This CCP record also has a hold time record and a second temperature after the hold. The individual pieces are measured by instant read probe thermometers and are different pieces on the belt before and after the hold time. There are three temperatures taken at at each verification interval before and after the hold time. The critical limit at the first check was below the critical limit. The second check was also below the critical limit. The HACCP plan uses FSIS Appendix A Time-Temperature Tables for validation of the CCP. The first check was below the critical limit but the hold time exceeded the necessary lethality time for pathogen of concern. Since the second temperature after the hold time is below the critical limit, is it possible to use the first temperature to justify the CCP has been met because the second temperatures are all higher than the first temperatures? what does your deviation plan say to do?  Time and temperatures work together, neither is a stand alone...........if the FSIS guide says the hold time you had plus the LOWEST temperature you had are sufficient then you MAY be ok Does this prove that temperature increases and thus the lowest temperature recorded and hold time at first temp check could be used to verify the CCP?

 

.......if time is ok but temp is too low, you could (in theory) experience rapid cell growth thus rendering your product More dangerous not less


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#4 cy2299

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Posted 31 October 2018 - 04:57 PM

Just to clarify, the Time-Temperature Table is appropriate for the meat that is being cooked. Also, the first temp-time combination check does meet the standard, but the second temp-time combination does not. The first check is done at a point which allows a hold time before the second check. The individual pieces, however, are not the same pieces being checked. Does the first or any check previous check that meets the CCP according to the Time-Temp Table indicate that the CCP is met or do both have to meet. The plan does not address this type of incident. What needs to be addressed is whether lethality has been met? 



#5 Scampi

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Posted 31 October 2018 - 05:25 PM

Can you quickly provide a link to the FSIS table?


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#6 cy2299

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Posted 31 October 2018 - 05:45 PM

Can you quickly provide a link to the FSIS table?

 

Here is the link:

 

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



#7 Scampi

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Posted 31 October 2018 - 06:46 PM

Is your HOLD time actually required, or do you just have to meet a minimum internal temperature?


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#8 cy2299

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Posted 31 October 2018 - 07:39 PM

Is your HOLD time actually required, or do you just have to meet a minimum internal temperature?

 

The CCP is a temperature independent of time, but as an example of the deviation would be 153 F and hold time of 2 minutes (120 seconds) would meet lethality standard for beef and chicken and turkey. However, turkey at 12% fat would not meet the lethality standard.



#9 Charles.C

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Posted 31 October 2018 - 08:03 PM

Hi cy,

 

The previous post is relevant. FSIS may have some specific compliance requirements ?

 

Offhand yr CCP monitoring methodology sounds highly complicated.

 

The usual approach in my area (not meat) is to initially base the CCP on a worst case situation which usually means the largest piece size of product in the given batch.

 

As per a previous post, to get meaningful answers, you may have to give a more detailed  description of yr process with an example of some measured numbers as compared to yr specific CCP requirement.

I am curious as to how you validated yr (unknown) CCP as this will usually define yr subsequent  monitoring procedure.

 

The tables referenced presumably assume a holding temperature at a constant temperature. If you do not have this then yr overall lethality is normally calculated using an integrated technique  unless you work on an absolute, minimal, single temperature, criterion which must be continuously achieved to ensure adequate lethality.

 

PS -  I note there is also a humidity factor to be included (somehow).

 

PPS - sorry i overlapped previous post. Not sure what you mean that CCP temperature is independent of time. Only true at the <10sec comment.


Kind Regards,

 

Charles.C


#10 Charles.C

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Posted 31 October 2018 - 08:22 PM

addendum

 

You seem to have ended up with  2 critical temperature limits (before/after holding time). This seems rather illogical.

 

As per yr comment, if the final, post-holding, temperature check on one piece fails then presumably that piece must have also failed the first check also.

 

IMEX (seafood), based on the validation data, the time is usually fixed at an appropriate level and the critical temperature is set slightly above the minimum referenced requirement to achieve the target lethality at that time. This safety factor attempts to ensure that the CCP will not fail.

 

Ideally, for convenience, the monitoring is focussed on the equipment generated temperature.


Kind Regards,

 

Charles.C


#11 cy2299

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Posted 31 October 2018 - 08:50 PM

addendum

 

I'm not quite clear if you are varying the holding time however, assuming the temperature is constant through the holding time the the CCP will logically be to meet/exceed the time specified in the reference at that temperature.

 

The typical approach in my area (seafood) would be to add a small safety factor to the reference time to avoid failing the CCP.

 

The CCP is validated by the same time temperature table or Appendix A and does not require the time because time is <10 seconds or instant as is stated on the tables.

 

 

What i am asking is that if a temperature was considered Iethal with the hold time than another temperature recorded after the hold time would either be irrelevant or not? (As the record does show that all of the first temperatures are lower than the temperatures recorded after the hold time).



#12 Charles.C

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Posted 31 October 2018 - 09:40 PM

The CCP is validated by the same time temperature table or Appendix A and does not require the time because time is <10 seconds or instant as is stated on the tables.

 

 

What i am asking is that if a temperature was considered Iethal with the hold time than another temperature recorded after the hold time would either be irrelevant or not? (As the record does show that all of the first temperatures are lower than the temperatures recorded after the hold time).

 

Hi cy,

 

I'm slightly confused. <10sec is equivalent to zero holding time.

 

The point of the heating stage is that the product experiences the minimum lethality requirement.

 

I would anticipate the referenced validation is based on the temperature at exit of heating stage (assumed constant).

IMEX the profile is rarely constant for short times. My validation required integrations.

 

What happens after the exit point is presumably another ball game entirely.


Kind Regards,

 

Charles.C


#13 cy2299

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Posted 01 November 2018 - 01:33 PM

Hi cy,

 

I'm slightly confused. <10sec is equivalent to zero holding time.

 

The point of the heating stage is that the product experiences the minimum lethality requirement.

 

I would anticipate the referenced validation is based on the temperature at exit of heating stage (assumed constant).

IMEX the profile is rarely constant for short times. My validation required integrations.

 

What happens after the exit point is presumably another ball game entirely.

 

The Table is the validation and the CCP is referenced as any temperature with < 10 seconds as it is considered instant lethality by the table. However, the temperature before the hold time was below the critical limit and so the time of dwell was considered with the temperature to compare with the Table. The combination of time-temperature recorded would have met the lethality standard on the Table. The question is does the second temperature which is higher tan the first but still under the critical limit need to be considered also? These temperatures are independent of each other as they are not the same piece but represent the same monitoring or verification check time. 



#14 Scampi

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Posted 01 November 2018 - 01:46 PM

Can you tell just a bit more about your product?  How processed is it prior to cooking (or as much detail as your comfortable giving)  

 

Generally speaking a cook on product is simply reaching the minimum internal temp and held momentarily (as even when the heat is removed, the law of thermodynamics tells us the internal temp will still increase prior to beginning the cooling curve).........

 

To be clear, you met the time AND temperatures on the chart for proven lethality?  If so, the second reading is redundant, and without know how long between probing temps, room temp, actual type of product

 

BTW testing 2 different pieces is probably not best practice...........you don't really know any true information as you don't know the initial temp at probe #1 to compare to probe #2


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#15 cy2299

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Posted 01 November 2018 - 02:12 PM

Can you tell just a bit more about your product?  How processed is it prior to cooking (or as much detail as your comfortable giving)  

 

Generally speaking a cook on product is simply reaching the minimum internal temp and held momentarily (as even when the heat is removed, the law of thermodynamics tells us the internal temp will still increase prior to beginning the cooling curve).........

 

To be clear, you met the time AND temperatures on the chart for proven lethality?  If so, the second reading is redundant, and without know how long between probing temps, room temp, actual type of product

 

BTW testing 2 different pieces is probably not best practice...........you don't really know any true information as you don't know the initial temp at probe #1 to compare to probe #2

 

 

Small pieces of meat < 2 oz (turkey, beef, chicken, pork).

 

Increased temps from first to second check show the increase in my opinion and law of thermodynamics as you stated. Which law is that by the way?

 

First temp did met lethality according to temp and hold time recorded. Second temp was still below critical limit but was at an area 57 seconds after the first temp which proved lethal by the Table.

 

Second temperature is taken to show instant temp lethality so that time need not be considered. The first temp is taken as so that it may suggest whether the product will need to be taken away from the line as it will not meet the lethality CCP and action can be done. The action was not done and now am considering the product at that time and beyond to be safe or not.



#16 Scampi

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Posted 01 November 2018 - 02:25 PM

Carlaw & Jaeger's 1947 Conduction of Heat in Solids..............the application of thermodynamics to cooking meat........

 

 

Just like at home.........if your cooking a beef roast and want it to be medium, it must come out of the oven at rare and be allowed to rest. The cooler external temperature forces the heat to penetrate the meat BEFORE the temperature can begin cooling. thereby raising the internal temp to a delicious medium. Granted, on a small piece the speed goes up rapidly, but that is why food manufacturers err on the side of caution and use a GUARANTEED internal temperature for lethality.

 

 

After rereading all your posts, I am repeating my original thought......your product did not meet your prescribed CCP AS WRITTEN nor does it appears a suitable deviation can be made. The product is therefore condemned

 

I still think your second temp check is unnecessary. The center of a 2 inch cube is either hot enough or it isn't. By allowing a second check, you are essentially delaying the implementation of your deviation (or recook, or line speed reduction or increase in oven temp)  BTW, you didn't mention your actual oven temp..........did you have a blip in the conveyor over time/temp that caused your product to miss the CCP values


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#17 cy2299

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Posted 01 November 2018 - 02:51 PM

Carlaw & Jaeger's 1947 Conduction of Heat in Solids..............the application of thermodynamics to cooking meat........

 

 

Just like at home.........if your cooking a beef roast and want it to be medium, it must come out of the oven at rare and be allowed to rest. The cooler external temperature forces the heat to penetrate the meat BEFORE the temperature can begin cooling. thereby raising the internal temp to a delicious medium. Granted, on a small piece the speed goes up rapidly, but that is why food manufacturers err on the side of caution and use a GUARANTEED internal temperature for lethality.

 

 

After rereading all your posts, I am repeating my original thought......your product did not meet your prescribed CCP AS WRITTEN nor does it appears a suitable deviation can be made. The product is therefore condemned

 

I still think your second temp check is unnecessary. The center of a 2 inch cube is either hot enough or it isn't. By allowing a second check, you are essentially delaying the implementation of your deviation (or recook, or line speed reduction or increase in oven temp)  BTW, you didn't mention your actual oven temp..........did you have a blip in the conveyor over time/temp that caused your product to miss the CCP values

 

The second check should not have been done when first temp is below critical limit and action should have taken place and the process would have been corrected and move on. However, action was not taken and am looking at product disposition.

 

So you think that the case cannot be made through the record and Carslaw and Jaeger heating application that temp increased from pre-hold to after hold and state that the first temp and hold time met CCP --end of story? 



#18 RennieSka

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Posted 01 November 2018 - 02:59 PM

I think in this case, as Scampi said,  its more a matter of following your current HACCP plan as written, because that's what it is meant for. If your plan states that if the 1st check fails it will be reworked or considered non-conforming, then you need to follow that protocol. 

 

As mentioned earlier in the thread you might want to take this opportunity to revisit your CCPs and corrective action plans in your HACCP in the event of a failed CCP at this step in the future. That might require more validation, and worst case scenario data, but if you think its reasonable to use the time/temperature table for your product its likely worth rewriting. 



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#19 Scampi

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Posted 01 November 2018 - 02:59 PM

I think in order to keep the product the Carslaw and Jaeger math isn't enough BECAUSE your not following your own procedures..........

 

 

Having said that, if this is a huge batch, and technically you've still met the FSIS proven time/temp (regardless of when) then I would also send sample for ecoli/listeria/salmonella to accredited lab with all affected product on hold pending disposition. I would agree that the product is probably safe...............this is a necessary expense (THAT SHOULD BE BILLED TO OPERATIONS) that has to be incurred.

if your talking about a small batch for your facility----bin it, let the operations department take the financial hit and be done with this

 

To put it in perspective, CFIA keeps recalling RAW breaded chicken because it MAY contain salmonella..............so since your product has already been cooked you need to ensure you've complete all of your due diligence before you even think about releasing this product

 

I will also point you at the MASSIVE recall involving pre cooked frozen veg from McCain...........millions and millions recalled........when the product should have been put on hold pending further testing

 

No matter the cost, the lab work IS ALWAYS cheaper than a recall


Because we always have is never an appropriate response!


#20 cy2299

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Posted 02 November 2018 - 03:12 PM

I think in order to keep the product the Carslaw and Jaeger math isn't enough BECAUSE your not following your own procedures..........

 

 

Having said that, if this is a huge batch, and technically you've still met the FSIS proven time/temp (regardless of when) then I would also send sample for ecoli/listeria/salmonella to accredited lab with all affected product on hold pending disposition. I would agree that the product is probably safe...............this is a necessary expense (THAT SHOULD BE BILLED TO OPERATIONS) that has to be incurred.

if your talking about a small batch for your facility----bin it, let the operations department take the financial hit and be done with this

 

To put it in perspective, CFIA keeps recalling RAW breaded chicken because it MAY contain salmonella..............so since your product has already been cooked you need to ensure you've complete all of your due diligence before you even think about releasing this product

 

I will also point you at the MASSIVE recall involving pre cooked frozen veg from McCain...........millions and millions recalled........when the product should have been put on hold pending further testing

 

No matter the cost, the lab work IS ALWAYS cheaper than a recall

 

Thanks for your comments. I agree with micro pathogen testing the product to ensure safety. 



#21 Charles.C

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Posted 02 November 2018 - 08:52 PM

Hi Scampi,

 

My humble apologies if over-suspicious but It is just, just possible that you are having a conversaion with a troll.


Kind Regards,

 

Charles.C


#22 Scampi

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Posted 05 November 2018 - 02:38 PM

Hi Scampi,

 

My humble apologies if over-suspicious but It is just, just possible that you are having a conversaion with a troll.

I hope not............said troll seems to be able to provide some real information that I can understand a newbie needing help with!!!!!!  Compared to some of the other completely off base posts I've seen on here, this one is pretty tame (remember the laundry detergent through food piping????)


Because we always have is never an appropriate response!


#23 cy2299

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Posted 06 November 2018 - 01:48 PM

Not a troll. Issue that needed experienced review and I appreciate it.



#24 Scampi

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Posted 06 November 2018 - 01:54 PM

Are you making progress with this issue Cy?


Because we always have is never an appropriate response!


#25 cy2299

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Posted 09 November 2018 - 05:09 PM

Progress is to know that it is a training issue more than likely at the monitoring level and not a real process issue that needs reassessment, Thanks







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