Seafood HACCP Monitoring of Gel Packs

I work for a warehousing company and have inherited a legacy Seafood HACCP plan. We have some suppliers that use gel packs as a cooling medium in the seafood shipments. Currently, the plan does not have monitoring activities written for this CCP. Thus far I have not been able to find much information on what is considered "adequate" or how to monitor other than thawing.

The FDA hazards and control guide states for fish delivered under chemical cooling media such as gel packs: there is an adequate quantity of cooling media that remain frozen to have maintained product at an internal temp of 40 or below through transit 

AND internal temps of fish at the time of delivery is 40 or below.

My question is since this is a visual observation, what is considered adequate if some ice packs are frozen and some are thawed, but product temps below the CCP? I would assume that if the product is below 40 the ice packs did their job. 

I should also note these products are still typically shipped on refrigerated trucks.

Any feedback would be greatly appreciated.

Thanks,

EKR

Hi EKR,

I'm a bit confused by the visual observation bit - are you using temperature probes to measure the temperature and get the -40 figure? Or just looking at it and visually assessing? I think as long as the product itself remains within the acceptable temperature parameters, this is whats important, regardless of the state of the cooling mechanism - as long as it does the job. I would do some validation though to ensure worst case scenarios are accounted for, i.e. small volume of product + longer journey etc.

Do you mean visual because the product is clearly frozen and you cannot probe the temperature of the product?

"The FDA hazards and control guide states for fish delivered under chemical cooling media such as gel packs: there is an adequate quantity of cooling media that remain frozen to have maintained product at an internal temp of 40 or below through transit "

That's your answer there, at least some of the gel pack must still be frozen in order to be within compliance, but the word "adequate" will be open to interpretation. The issue is that if some are completly thawed, the product could theoretically begin to rise in temp quickly and enter the danger zone, which for seafood is quite low. By not having at least some of the pack still frozen, the product is at greater risk. 

Are the refers on remote monitoring? Would the driver know the refer wasn't working BEFORE he arrived at your dock?

MIFSQN,

All product is pulp temped at receiving. Cases are temped on the outside of the pallet and the internal portion of the pallet as well.

I used to work at a seafood warehouse. We would bring shipments from the trucks as well. But they were covered in ice, not gel packs. So I would not only check the temperatures (below 40), but also insuring visually its entirely covered in adequate ice. (even if the temperature was withing the control limits, i would still add ice to help keep it in limit). 

I would have thought that a CL of <=40degF was sufficient anyway. Not so sure about sampling though ?

Hi EKR,

 

I'm a bit confused by the visual observation bit - are you using temperature probes to measure the temperature and get the -40 figure? Or just looking at it and visually assessing? I think as long as the product itself remains within the acceptable temperature parameters, this is whats important, regardless of the state of the cooling mechanism - as long as it does the job. I would do some validation though to ensure worst case scenarios are accounted for, i.e. small volume of product + longer journey etc.

Do you mean visual because the product is clearly frozen and you cannot probe the temperature of the product?

 

"The FDA hazards and control guide states for fish delivered under chemical cooling media such as gel packs: there is an adequate quantity of cooling media that remain frozen to have maintained product at an internal temp of 40 or below through transit "

 

That's your answer there, at least some of the gel pack must still be frozen in order to be within compliance, but the word "adequate" will be open to interpretation. The issue is that if some are completly thawed, the product could theoretically begin to rise in temp quickly and enter the danger zone, which for seafood is quite low. By not having at least some of the pack still frozen, the product is at greater risk. 

 

Are the refers on remote monitoring? Would the driver know the refer wasn't working BEFORE he arrived at your dock?

We require shippers to have a time/temperature recorder for all fresh refrigerated loads. I believe some suppliers are overly cautious and ship with gel packs. It was brought up in an inspection that we had no monitoring information or corrective actions for the use of gel packs in our HACCP plan. I want to ensure the correct verbiage is used. I understand there are 2 requirements for gel packs: the frozen state of the gel packs and temperature of the product.

I believe FoodSafetyPlanet has answered my question.

Thanks everyone.

So how about the sampling ?

EKR,

Glad I could help.

Charles makes a good point: you also need a systematic approach since there's a lot of subjectivity in the process. 

I recommend talking to your supplier about their validation studies or using results from similar cold chain tests. This data, along with your results, will help define "adequate". 

At the time of delivery, all products are pulp temped. If we talk about  the cases    they are temped both on the outside of the pallet and on the inside of the pallet.

At the time of delivery, all products are pulp temped. If we talk about  the cases    they are temped both on the outside of the pallet and on the inside of the pallet.

3-year old thread.

This Post seems to mimic post 4 which itself is semi-meaningless linguistically to me ("pulped" = ??)

Spam ?

From fish and fishery products hazards and controls guidance (page 12)

• It is now recommended that shipments of scombrotoxin-forming species received under gel packs be checked for both adequacy of gel packs and internal product temperature;

Link to guidance: https://www.fda.gov/.../80637/download