The defined requirements are curious though I expect it may be related to campylobacter, a large focus of the EMP in poultry processing.
Fresh produce should be refrigerated as soon as possible. Refrigerators should be set at between 0°C and 4°C; a thermometer will be needed to check the temperature. Campylobacter does not grow below 4°C.
To the requirements:
852/2004 Article 5 point 1
B1. Food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles.
852/2004 Annex II Foodstuffs: Chapter IX point 3
B2. At all stages of production, processing and distribution, food is to be protected against any contamination likely to render food unfit for human consumption, injurious or contaminated in such a way that it would be unreasonable to be consumed in that state.
852/2004 Annex II Foodstuffs: Chapter IX point 5
B3. Raw materials, ingredients, intermediate products and finished products likely to support the reproduction of pathogenic micro-organisms or the formulation of toxins are not to be kept at temperatures that might result in a risk to health. the cold chain is not to be interrupted.
However, limited periods outside temperature control are permitted, to accommodate the practicalities of handing during preparation, transport, storage, display and service of food, provided that it does not result in a risk to health.
B.1 to B3. Compliance regarding chilling and the cooling curve.
Chill meat and maintain the temperature of meat at or below legal limits.
B1. to B3. Good practice.
After slaughter and dressing the internal temperature of an animal carcase will generally be between 30°C and 39°C. This warm and wet surface provides ideal conditions for growth of food poisoning organisms. Chilling and drying restricts microbiological activity as well as chemical and physical changes that cause deterioration and spoilage. The reduction of internal carcase temperature to below 7°C for red meat, 3°C for offal and 4°C for white meat occurs along a ‘cooling curve’.
If the environment in which the meat enters the processing area is at or below the specified temperature (and is monitored to verfiy) and is processed in an environment below 12oc (and is monitored to verify) and is processed and moved without delay into a cold store below 2oC (which is monitored to verify), is there a legal requirement to also measure the temperature of the meat during processing and a legal requirement to achieve the stated temperatures at all stages of the processing?
I see the logic of what you're saying, but yes you need to maintain the temperature of the meat and evidence compliance by measuring the meat itself. Even if the environment is controlled in such a way to keep the meat within temp, you'd still need to directly verify. You mentioned "processed and moved without delay" - whilst this could be an argument for solely environmental control, the reality of the matter is that you can't guarantee that will happen. I'm currently with a large poultry processor and previously worked in a raw-cooked meat site, and I'm sure it's the same in anything - delays happen. Take a raw chicken inner fillet for example, if there was even a slight delay in production for whatever reason, it doesn't take long at all for the product to breach the temperature parameters. You wouldn't be able to verify that properly though without measuring the fillet itself.
Regarding the "legal requirement to achieve the stated temperatures at all stages of the processing" - see Annex II chapter IX point 5 above. You can create a concessionary procedure but it would need to be based on risk and validated; would depend on your product/process.
I'd recommend creating a temp control procedure for the product itself. Of course it will depend on your product/process; a 2kg beef silverside is more temp stable than chicken inner fillets. Also consider any scheme and customer requirements you have that relate to this.