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HACCP - When Cooking is a Control but Not a CCP.


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#1 terrine1

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Posted 20 November 2018 - 01:33 PM

We produce haggis which is cooked to 84 degrees C for 65 minutes now, to comply with vac pack guidance. We're currently looking at increasing the salt levels in the aqueous phase as the vac pack control to allow us to reduce the cooking time/temp combination as we would like to reduce energy costs. we produce our haggis in an area we consider raw and we sell it as raw, with clear cooking instructions and the additional warning statement of 'This Product Must Be Cooked Prior to Consumption'; as a result we do not consider it to be a CCP with our control measure being that the product undergoes a final cook by the consumer. We have operated this way for several years and have been audited by FSA, FSS, BRC and numerous retailers and this has never been raised as an issue however we recently had an FSS audit carried out by a new auditor and he is insisting that the control is unacceptable because we can't rely on the customer to cook it properly and we need to consider it a CCP. 

 

We would prefer not to because of the raw area the haggis is produced in - please can someone advise on what they think and if there is another control/validation we can use to justify why it isn't a CCP?

 

Any help much appreciated.

 

Thank you.



#2 Scampi

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Posted 20 November 2018 - 01:47 PM

To try and shed some light on your quandary, I will give you this example;

 

There is a large company in Canada that produces breaded UNCOOKED chicken products........most have undergone a flash fry so the product may appear cooked.........we all know raw poultry is susceptible to salmonella..........and that the consumer SHOULD cook it properly............but people do not read instructions NOR does anyone actually know how to cook anymore..........packages of these products ALL clearly state DO NOT MICROWAVE.....but people do, and microwaves do not heat evenly so people keep getting sick, and there continues to be recalls for this RAW product.  CFIA has imposed new rules for these processors to meet a ZERO rate of salmonella, Now, I agree that we are hopefully producing salmonella free poultry, but swabbing every carcass is not feasible (and not just from a financial perspective).

I just include this as a level of understanding that just because it was OK in the past, doesn't mean regulations/issues remain static.

 

Are you doing ANY finished product testing to support your process?  Are you sampling incoming raw materials for e coli and the like?


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#3 pHruit

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Posted 20 November 2018 - 02:35 PM

Is there a possibility of e.g. shigatoxin production between your cook and the consumer cook, if your cook didn't work correctly and the haggis had STEC problems via raw materials? And would the recommended cooking instructions destroy it anyway? (I've been a vegetarian for about 20 years so a long time since I cooked a haggis!).

 

I'm baffled by the position that consumers can't be relied upon to safely cook things - this sort of logic leads down a path where no one will be able to produce any raw food at all?!

Are your customer cooking instructions designed to include a safety margin (and the usual "check food is piping hot before serving" disclaimer)?

In general consumers can be relied upon to really challenge the limits of time/temp abuse for storage, cooking and pretty much everything else, but if you can show that the safety factor is significant that may help reassure FSS. 

It may also be possible to speak to someone else at FSS to get a second opinion? If you have the HACCP system in place to back it up, as would seem to be the case given the list of other auditors who've not raised any concerns (including the ultra risk-averse retailers) then it does suggest that one particular auditor could have misunderstood something fundamental and gone a bit off-piste.

It's a risky approach as obviously don't want to upset the auditor if the same one is likely to be back next time, but equally if he has a significant misunderstanding then both you and FSS (and indeed other FBs) need to get it corrected.



#4 Scampi

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Posted 20 November 2018 - 04:03 PM

pHruit

 

"I'm baffled by the position that consumers can't be relied upon to safely cook things - this sort of logic leads down a path where no one will be able to produce any raw food at all?!

 

 

I know I know, recall after recall after recall...................................this is a direct result from pulling Home Economics from public schools

 

http://inspection.gc...3/1531254524999

 

OMG 7 log reduction for RAW Friggin poultry!!!!!!!!!!!!!!!!!!!

 

I digress, once one country imposes rules like above, it becomes the new international standard


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#5 pHruit

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Posted 20 November 2018 - 04:10 PM

7 log?!

We need to all pitch in on a bulk order of dictionaries and start posting them out to regulators with the word "raw" bookmarked...



#6 Scampi

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Posted 20 November 2018 - 04:17 PM

:roflmao:  :roflmao:  :roflmao:  :roflmao:  :roflmao:  :roflmao:

 

If only it were that simple........................I fear a new benchmark has been made.........but alas recalls continue to happen on this product type since this was implemented...........um wonder why??? oh yeah, there's not enough anti microbial in the world to consistently reach this post!


Because we always have is never an appropriate response!


#7 Charles.C

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Posted 21 November 2018 - 02:39 AM

We produce haggis which is cooked to 84 degrees C for 65 minutes now, to comply with vac pack guidance. We're currently looking at increasing the salt levels in the aqueous phase as the vac pack control to allow us to reduce the cooking time/temp combination as we would like to reduce energy costs. we produce our haggis in an area we consider raw and we sell it as raw, with clear cooking instructions and the additional warning statement of 'This Product Must Be Cooked Prior to Consumption'; as a result we do not consider it to be a CCP with our control measure being that the product undergoes a final cook by the consumer. We have operated this way for several years and have been audited by FSA, FSS, BRC and numerous retailers and this has never been raised as an issue however we recently had an FSS audit carried out by a new auditor and he is insisting that the control is unacceptable because we can't rely on the customer to cook it properly and we need to consider it a CCP. 

 

We would prefer not to because of the raw area the haggis is produced in - please can someone advise on what they think and if there is another control/validation we can use to justify why it isn't a CCP?

 

Any help much appreciated.

 

Thank you.

 

Hi terrine,

 

I suspect yr product looks to have fallen into a sort of (haggis) black hole from a CCP POV.

 

I am sort of curious how you justify the "raw". (Not vacpac related but this is a well-known label  "fudge" in some other food areas" as illustrated post 2.)

 

Vacpac not my area of expertise but  I am sort of surprised yr heat step is not expected to be a CCP if mandated for vacpac safety. I recall there is a classic UK publication on vacpac requirements but which probably does not include haggis.

 

Is it really not fully cooked already after yr heat treatment ??

 

On the other hand, if you can justify the "raw" i think  there are examples in the Literature noting the consumer's role/responsibility in ensuring a/their safe product. I think I recall at least one case of an intuitive  risk assessment being made on the chance of failure of such logic.


Kind Regards,

 

Charles.C


#8 terrine1

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Posted 21 November 2018 - 10:13 AM

Thank you to everyone for your replies - much appreciated. The safety of the haggis isn't the issue - it's cooked for over an hour at a core temp of 84 C and yes it gets regularly tested and all micro counts are extremely low - we have no concerns over this. We cook well over the required time/temp to ensure it is safe however may be reducing this and increasing the aqueous salt instead to allow us to comply with vac pack rules and save on energy costs. It will still be cooked - just nowhere near as long  so the same issue applies or in fact it will be much more of an issue because at this time it's cooked to perdition whereas in theory it won't be if we increase the salt. The reason we justify it as being raw is because it is produced in a raw area - we're not set up to have a high risk or even high care area; all labelling provides cooking instructions which are greater than actually required to allow for a margin of error plus the statement 'must be piping hot throughout' plus the statement 'this product must be cooked prior to eating'.

 

We also do intensive shelf-life testing and have a margin of error of approx 30% over & above the stated life on pack plus include storage and customer abuse temperature wise.

 

I don't understand the poultry one at all - there surely has to be some reliance on customers? The world has gone mad......

 

Charles - could i possibly trouble you to point me in the right direction of where i could find the intuitive risk assessment you refer to please? I'm hopeful that it may give me inspiration!

 

Thank you :) 



#9 Charles.C

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Posted 21 November 2018 - 12:43 PM

Hi terrine,

 

Thks for comments.

As I understand, yr thermal process is designed to produce a micro. validatable "fully cooked" product, ie nominally RTE.

But which is then labelled/commercialized as "raw" due "environment".

Regardless of any mislabelling legalities(?) I can anticipate such a dichotomy represents a definite haccp challenge to an auditor. It certainly would to me.  :smile:

 

Will do a search for the "intuitive" paper mentioned and upload in next few days if located. Maybe other posters here have encountered similar qualitative/quantitative mullings ??

 

JFI, IIRC, some FS standards require a specific documented validation by the processor  that the labelling requirements for a raw item, assuming a "competent" consumer, should  assure a fully cooked/safe product.


Kind Regards,

 

Charles.C


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#10 MsMars

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Posted 21 November 2018 - 06:40 PM

I was baffled when the USDA began enforcement for salmonella levels in RAW poultry... I always felt slighted because how is it the processor's fault? Sure a bird can become contaminated during slaughter, but FAR more likely that the bird was harboring before it even arrived. There are SO many factors that contribute to pathogen harborage/contamination in a bird before it even makes it to slaughter. People wonder why processors use so many chemicals on the birds, but then call for more controls when an outbreak occurs. And now that I'm on the feed side of things, I feel as though it's only a matter of time before intensive testing of feed for pathogens will be required. 

 

I could go on and on about this subject... 



#11 Scampi

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Posted 21 November 2018 - 07:06 PM

Couldn't agree more MsMars, but I really do think this nonsense started when people stopped learning/being taught how to cook. A good home thermometer costs $10 and google will tell you what temperatures are safe to cook poultry to ensure any pathogens have been killed, but no one expects people to take care of themselves anymore.

 

 

 

Hopefully it doesn't escalate to pathogen testing in feed. The part of Canada i'm in right now has mandatory testing on all corn coming into the feedmills as there is a horrible toxic mold on the corn...........now that is something now one wants in feed

 

http://thesarniajour...strophic-level/


Because we always have is never an appropriate response!


#12 MsMars

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Posted 21 November 2018 - 07:12 PM

Hopefully it doesn't escalate to pathogen testing in feed. The part of Canada i'm in right now has mandatory testing on all corn coming into the feedmills as there is a horrible toxic mold on the corn...........now that is something now one wants in feed

 

http://thesarniajour...strophic-level/

 

Unfortunately we are seeing the same historically high levels of DON here in the Midwest as well.  No federally mandated testing required  - for now. 



#13 Scampi

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Posted 21 November 2018 - 07:14 PM

We've got really cold temps today    -13C for tonight, and still corn in the fields. If mine tested positive for the mold I think i'd just sent the whole field on fire!

 

The feed mills here are testing every wagon......one positive and it's all getting rejected


Because we always have is never an appropriate response!


#14 Charles.C

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Posted 21 November 2018 - 07:34 PM

Haggis is a savoury pudding containing sheep's pluck (heart, liver, and lungs); minced with onion, oatmeal, suet, spices, and salt, mixed with stock, and cooked ..

 

Raw Poultry = ?

 

It's a Long and Winding Road . :happydance: :happydance:


Kind Regards,

 

Charles.C


#15 Scampi

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Posted 21 November 2018 - 07:49 PM

Lol Charles

 

It started with my comment about "raw" things having to meet the same microbial/pathogen standard as fully cooked RTE or RTH which is where the haggis appears to have fallen

 

 

I've never heard of offal referred to as "pluck" but it sure does sound better!!!!


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#16 terrine1

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Posted 22 November 2018 - 10:24 AM

Thank you Charles, I appreciate your help & comments.. Not quite the same as raw poultry as you say  :giggle: but still, an interesting dilemma.

 

Kind regards.






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