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Bakery, Identification of Low Risk and High Care

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Posted 05 December 2019 - 10:16 AM

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?




Hi kettlecorn,


I will attempt to elaborate.


As I understand FSMA typically requires the baking step to be a Preventive Control (eg Ch6/FSMA Draft Hazard Analysis Guidelines).

I deduce this implies that FSMA do not agree with suggestions like "output quality failure" can justify that inadequate baking does not present a potential micro.hazard to the consumer.


Prior to FSMA, FDA implemented (traditional) haccp based on Codex/NACMCF. If my above  interpretation  is accurate and FDA's (then) opinion was unchanged from current, I anticipate that FDA would  favour a CCP at the baking step .


But I have not seen any published examples of FDA-authorised baking haccp plans going back to this period. Hence my query in Post 21.

(A random Literature scan of around 10-15 studies indicated the majority showed Baking CCPs. A few [2-4] did show absence, but with no explanation.)

Kind Regards,




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Posted 17 December 2019 - 11:14 AM

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.


I used to work in an artisan bakery, we never had one complaint.  Also even a doughy centre if it did happen does not mean food safety risk as bread will be nearer 90oC to get a fully cooked centre.

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