Bakery, Identification of Low Risk and High Care
Hi,
We are currently trying to improve our standards to a BRC level.I was little confused on define areas as Low Risk,High Care and High Risk.
All products are frozen desserts and are ready to eat once defrosted. Ingredient used are cream, pasteurized egg, flour, chocolate etc. I believe all ingredients are safe to eat as are either ready to eat or have been pasteurized.
Even though processes such as heating and baking occur in the bakery, these are for rising flour and melting chocolate not to reduce biological hazards.
Please could someone advise if the whole production process can be just defined as High Care. Furthermore would you agree that CCP's would only be freezing down and raw material storage temperature as baking is not reducing microbes in the case.
Many Thanks,
T
BRC has a decision tree on page 93 to help with this very issue.
Following this decision tree has lend me to believe all areas would be determined as High Care. Raw ingredients need to be stored at the correct temperatures to reduce microbial growth. Cooking process used for cakes etc are for quality reasons ( rising) and not for the purpose of heat treating as raw ingredients do not need to be cooked to be eaten.
please could somebody share there views on this.
Many thanks,
T
Your product is an interesting one! Bakeries traditionally would be considered low risk because the product cannot support the growth of microorganisms but bakery products with cream can. Flour, however, cannot be a high care ingredient in its raw state as it has not undergone a kill step sufficient to kill off pathogenic bacteria.
I think the area you add cream would have to be high care. The question would be on whether you should cook your cakes into your high care area. In some ways it feels like overkill but in others, pathogens naturally present in the flour would be a growth risk with that cream.
It might be good to get a BRC or CB viewpoint as resolving this may include walls and cost!
Thank you GMO, So the only growth material would be the flour. As the milk, cream and eggs used are all pasteurized before arriving on site.
This would mean that baking would become a CCP if this is a growth material ? Currently all baking is over 70C for much more than 2 mins. When baked items are coming out the oven if the product had been cooked for less time or less temperature this would affect product quality visable and would automatically get rejected.Currently baking occurs in a separate area to the rest of the processes.
Many Thanks,
T
Also i forgot to mention raw material flour and cakes mixes are heat treated before arriving on site. Specification states an absents or maximum of 100 cfu/g.
Thank you GMO, So the only growth material would be the flour. As the milk, cream and eggs used are all pasteurized before arriving on site.
This would mean that baking would become a CCP if this is a growth material ? Currently all baking is over 70C for much more than 2 mins. When baked items are coming out the oven if the product had been cooked for less time or less temperature this would affect product quality visable and would automatically get rejected.Currently baking occurs in a separate area to the rest of the processes.
Many Thanks,
T
No, you misunderstand me. The raw flour is a source of pathogens. The cream, used without further heat treatment, can be a growth medium. The baking us unlikely to be a CCP as, you rightly point out, baking inadequately wouldn't give you a cake.
My concern is that the raw flour will carry pathogens like Salmonella. If there is no barrier between the raw flour and the finished cakes with cream and no restriction on staff moving from one area to another, there is a risk in the cream even if it's pasteurised. Does that make sense?
That does make sense, Many thanks.
IMO, the classification of yr various pasteurisations may well be contentious.
The relevant haccp question is what may go wrong ? And the consquences.
Hi Charles.C,
Pasteurization occurs before purchase of the raw material of Egg and Milk. and Heat treatment of Flour / Flour mixes. So this is covered by Supplier Approval. The CCPs within the business would be storage of raw materials where the temperature of chilled ingredient are checked before use and the chillers are regularly checked. The other CCP within the business would be blast chilling and the time taken to chill down to temperature.
kind regards,
T
Hi Charles.C,
Pasteurization occurs before purchase of the raw material of Egg and Milk. and Heat treatment of Flour / Flour mixes. So this is covered by Supplier Approval. The CCPs within the business would be storage of raw materials where the temperature of chilled ingredient are checked before use and the chillers are regularly checked. The other CCP within the business would be blast chilling and the time taken to chill down to temperature.
kind regards,
T
Hi T,
Sorry I missed post 6,
Basically you need to follow the steps in the brc chart although "exceptions" to the text occasionally pop-up where a possible mismatch occurs. Then brc have had the habit of adding further subtleties. Hence GMO's suggested cross-checking.
I predict the baking step will be a CCP for BRC regardless of the inputs' status. But I could be wrong.
I predict the baking step will be a CCP for BRC regardless of the inputs' status. But I could be wrong.
I doubt it. In bread baking the flour will contain pathogens but at the temperatures required to kill pathogens you don't have bread. It will be similar with cakes.
Heat treatment of Flour / Flour mixes.
Really? All your flour is heat treated? Are you sure?
I doubt it. In bread baking the flour will contain pathogens but at the temperatures required to kill pathogens you don't have bread. It will be similar with cakes.
IIRC, there is another BRC baking thread here whose audit demonstrated dogmatism to the cooking/CCP cause. Perhaps not all BRC auditors are identical.
Really? All your flour is heat treated? Are you sure?
Yes, seemed a bit unlikely to me also.
Hi GMO,
See ^^^^^
I doubt it. In bread baking the flour will contain pathogens but at the temperatures required to kill pathogens you don't have bread. It will be similar with cakes.
I continue to not see this as a HACCP based level of certainty. If you make that argument, then any customer complaint regarding undercooked or "doughy" items is a CCP failure with food safety implications...
I continue to not see this as a HACCP based level of certainty. If you make that argument, then any customer complaint regarding undercooked or "doughy" items is a CCP failure with food safety implications...
The required temperature to have bread is a good 20 degrees above where the safety margin is. It's the same reason why biscuit baking isn't a CCP or potato chip frying. At temperatures where vegetative pathogens aren't killed, you don't have a product.
The required temperature to have bread is a good 20 degrees above where the safety margin is. It's the same reason why biscuit baking isn't a CCP or potato chip frying. At temperatures where vegetative pathogens aren't killed, you don't have a product.
Actually IIRC the safety margin for B.cereus spores is marginal/nil and for some other bacilli even worse. But I agree this is usually considered a haccp side-issue/controllable at raw material end.
Regardless the (conceptual) debate will no doubt go on. :smile:
Actually IIRC the safety margin for B.cereus spores is marginal/nil and for some other bacilli even worse. But I agree this is usually considered a haccp side-issue/controllable at raw material end.
Regardless the (conceptual) debate will no doubt go on. :smile:
I'm sure it will but that's where the HACCP identification of hazards is vital. Are you trying to control bacillus through baking? it's extremely doubtful. There are few cooking processes where bacillus will not survive.
No, you misunderstand me. The raw flour is a source of pathogens. The cream, used without further heat treatment, can be a growth medium. The baking us unlikely to be a CCP as, you rightly point out, baking inadequately wouldn't give you a cake.
Hi GMO,
I find it very interesting that heat treatment is not necessarily a CCP in bakery. I don't have any experience of it, but I thought (before) that any "kill step" is a CCP. You opened a new world for me...
My question is, even though it's not written as CCP, it still needs to be monitored as a CCP, since an insufficient temperature wouldn't make a cake. So does it really matter, whether to mark it a "ccp" in HACCP plan or not?
Thanks a lot.
Hi GMO,
I find it very interesting that heat treatment is not necessarily a CCP in bakery. I don't have any experience of it, but I thought (before) that any "kill step" is a CCP. You opened a new world for me...
My question is, even though it's not written as CCP, it still needs to be monitored as a CCP, since an insufficient temperature wouldn't make a cake. So does it really matter, whether to mark it a "ccp" in HACCP plan or not?
Thanks a lot.
I'm not sure why this should be so surprising. GMO's point is simply as such: A CCP demands a validated limit which can be corrected for. For the product named (and I should also say our food safety plan looks much the same) there can simply be no product unless the limits meet or exceed the expected minimal. Hence, there is no CCP at this step.
"Kill step" and CCP are not interchangeable.
BostonCream,
I should say, however, to answer your question more fully, you still need to demonstrate this in your Food Safety Plan. We use a peer-reviewed, academic study as validation to prove that our product simply cannot be a product unless the minimal limits are far exceeded. All of this is contingent on product and, in some cases, on the particular processes used. As this thread shows, a lot of it comes down to the context of analysis.
Baking (and FSMA) is not my area but, as i understand, FSMA apparently do regard the baking step as a "kill step" (eg for Salmonella ex Flour) resulting in it (typically?) being an expected Preventive (Process) Control.
IMO, contrary to Post 19, from a Codex POV, the above would come very close to a justification for a classification as a CCP regardless of the "get-outs" previously discussed in this thread..
Is there any evidence for FDA supporting baking not being a CCP within the traditional haccp scheme?
There are innumerable previous threads on this topic so I just add this brief (2015) one as, I think, a fairly typical "for and against" -
Hi Charles,
FSMA is my area. Therefore I don't understand this statement:
"Is there any evidence for FDA supporting baking not being a CCP within the traditional haccp scheme?"
It is contradictory in view of HARPC, especially the part about "traditional HACCP scheme" and FSMA. Can you perhaps elaborate?
Regards.
there can simply be no product unless the limits meet or exceed the expected minimal.
This may just be my perspective then having never done a baked item, do consumers NEVER complaint about "undercooked" items? I find it hard to believe that small bakeries never let a product out the door that was baked on the outside but still "doughy" in the middle. Hence why this has always bothered me, because if the validation is "cooked bread gets hot enough", then a consumer complaint of undercooked bread carries some food safety weight? Yet that would be dismissed as a quality complaint for sure.
If internal temperatures of products coming out of the oven meet the required temperatures, then it's a consumer "perception" issue as to whether or not the item is "undercooked".
But then again, we do buns, rolls and bagels. If the internal temps are not met, we dispose of the products, because of quality issues, i.e. "undercooked". They are going to be flat, way too light on color, etc.
That being said, FDA (FSMA) requires some kill step for identified hazards in flour. You have to show that your baking process will achieve the appropriate time and temp for salmonella eradication.
I have the FDA inspection experience to back that statement up.
Marshall
This may just be my perspective then having never done a baked item, do consumers NEVER complaint about "undercooked" items? I find it hard to believe that small bakeries never let a product out the door that was baked on the outside but still "doughy" in the middle. Hence why this has always bothered me, because if the validation is "cooked bread gets hot enough", then a consumer complaint of undercooked bread carries some food safety weight? Yet that would be dismissed as a quality complaint for sure.
Hi FFF,
I take your point, as I wasn't trying to claim any sort of expertise about baking. My insight, such as it is, regards another product. The internal temperature of the product, simply to exist, has to be 100 degrees over minimal Celsius limits for a pathogen kill step. Otherwise, as I say, there can simply be no product.
I fail to see how this could possibly be a CCP.
The principle can be applied elsewhere, depending on the product. In the example you provide, it appears to me there are other quality issues at stake.
Regards