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Refrigeration Conditions CCP's action Limits

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DRFSM

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Posted 27 January 2020 - 12:05 PM

Good morning all,

 

In 90% of places i have worked over 20yrs industrial refrigeration units have had CCP's set at around <4.4°c which would be displayed on the doors as CCP's (obviously) in the event of temperatures becoming 4.4°c the QA's would then start to investigate cause (doors open, fault probes, compressor trip outs etc) and then take actions accordingly (temperature monitoring of products / materials in chillers) and generally take further action to move said materials and products to another more suitable chilled environment should temperature rise in products to around 7.5°c for and up to 4hrs until such times as the chilled area goes back in to spec.

 

Although this to me is a pretty straight forward general setup with variations in the CCP being just a control point and etc dependant on the hazards identified during HACCP.

 

This system has always been accepted by BRC auditors and EHO / customers alike.

 

However..........

 

Today I had an EHO come along and question me as to why i had my CCP's as <4.4°c informing me that they would be happy for it to be 8°c

 

This to me is wrong???? first danger zone is 5-63 right so straight away thats an issue right? and secondly for our product lines we have certain fish that can create Histamine toxin formation in fish which need to be stored between 3 and 4°c 

 

Anyone able to swing my head back around to the light and point me straight...or have an idea on what they are talking about? 

I have tried to contact them again to get more clarification, but as of yet no response.

 

Kind regards



pHruit

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Posted 27 January 2020 - 12:17 PM

<8°C is the general legal requirement in the UK for "chilled" - see e.g. Schedule 4 of The Food Hygiene and Food Safety (England) Regulations 2013.

I completely agree with you that I want the action limit to be below this - if nothing else then I want time to do something about it before breaching the limit. We use 5C (products are only chilled for quality reasons, no safety implication) and EHOs, auditors etc always been happy with this approach.  

 

The regs don't always cover specifics well (although you'll note that the reference above excludes products within the scope of 853/2004), but equally that doesn't absolve a food business of its obligation to manage to a tighter tolerance where required to make sure food is safe, e.g. for general compliance with Article 14 of 178/2002, which sounds like it could apply in your case.

It's therefore a little unsettling that your EHO seems to have missed this point! Hopefully they're just saying that you "could" rather than "should" increase your upper limit, in which case you can politely ignore them and hope they've got their heads screwed on better next time they visit ;)



Charles.C

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Posted 27 January 2020 - 09:10 PM

Good morning all,

 

In 90% of places i have worked over 20yrs industrial refrigeration units have had CCP's set at around <4.4°c which would be displayed on the doors as CCP's (obviously) in the event of temperatures becoming 4.4°c the QA's would then start to investigate cause (doors open, fault probes, compressor trip outs etc) and then take actions accordingly (temperature monitoring of products / materials in chillers) and generally take further action to move said materials and products to another more suitable chilled environment should temperature rise in products to around 7.5°c for and up to 4hrs until such times as the chilled area goes back in to spec.

 

Although this to me is a pretty straight forward general setup with variations in the CCP being just a control point and etc dependant on the hazards identified during HACCP.

 

This system has always been accepted by BRC auditors and EHO / customers alike.

 

However..........

 

Today I had an EHO come along and question me as to why i had my CCP's as <4.4°c informing me that they would be happy for it to be 8°c

 

This to me is wrong???? first danger zone is 5-63 right so straight away thats an issue right? and secondly for our product lines we have certain fish that can create Histamine toxin formation in fish which need to be stored between 3 and 4°c 

 

Anyone able to swing my head back around to the light and point me straight...or have an idea on what they are talking about? 

I have tried to contact them again to get more clarification, but as of yet no response.

 

Kind regards

 

Hi DRFSM,

 

It is likely that the specific choices of 4.4 and 8degC were/are to some extent arbitrary and reflective of evaluated refrigerator capabilities + microbiological factors +(maybe) shelf lives. Can try this older thread -

 

https://www.ifsqn.co...ree/#entry54153

 

 

Also see this multiply comparitive thread/extended discussion -

 

https://cooking.stac...er?noredirect=1

 

Above useful link still working on 210621 however i have added a pdf version below in case link fails -

Attached File  food safety - Why do fridge temperature standards between US and other countries differ_ - Seasoned Advice.pdf   84.03KB   8 downloads


Edited by Charles.C, 20 June 2021 - 08:23 PM.
added pdf

Kind Regards,

 

Charles.C


DRFSM

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Posted 06 February 2020 - 03:13 PM

Thanks guys, appreciate the response.

 

My EHO clearly doesn't understand our product groups i think, the raw fish which are sussceptable to histamine toxin formation need to be stored below 3°c so having a CCP at 8 is mental i think for my chillers. 

Some of our fish can be stored at 4-5°c and although there saying 8°c i think my CCP and action points are totally valid still.

 

Not too low to freeze product but low enough to keep at the bottom end of <3.4°c and well below 4-5°c at all times. 

 

Perhaps rather than displaying the actual CCP for area refrigeration as set at 2°c maintaining temperatures of <4.4°c i should just say <4 to not confuse them LOL



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Posted 06 February 2020 - 03:40 PM

Scombrotoxin formation is more commonly associated with much higher temps than 8°c, more like 21°c or greater and is very unlikely to occur at  temps between 4-10. If this is your only concern than a critical limit of less than 8 should be fine for a raw product. Additionally, most hazardous microorganisms do not come to significant log phase until temps exceed 10 (days vs hours).  


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DRFSM

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Posted 07 February 2020 - 09:29 AM

Scombrotoxin formation is more commonly associated with much higher temps than 8°c, more like 21°c or greater and is very unlikely to occur at  temps between 4-10. If this is your only concern than a critical limit of less than 8 should be fine for a raw product. Additionally, most hazardous microorganisms do not come to significant log phase until temps exceed 10 (days vs hours).  

 

Well my understanding of the species being scromidae family such as tuna the bacteria is commonly found and thus thew fish is supposed to be frozen or brought down to freezing within so many hrs. raw variants are stored in ice trays again to keep down at that freezing point or close to. i read somewhere (maybe on fish supplier) that they deem a ccp of <3.4 to prevent IF bacteria is present the formation of histamine toxin which is not eradicated during a cook process.

 

Either way, 8°c for refrigerated mackerel and other species of that family or susceptible to toxin formation shouldn't be at that temp ever. raw mackerel shelf life untreated around 3 days from defrosted.

 

im happy with my system. i test for histimine also and not found anything as of yet (fingers crossed) but i may change CCP values to be 4 digit rather than 2 decimal places as i guess that may not sit in their head as normal even though scientifically relevant i think.



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Posted 07 February 2020 - 04:43 PM

Pathogenic bacteria (e.g. Morganella morganii, E.coli, Salmonella ) shall also be happy if you change your cold room set point  to 8°C   :spoton:  :spoton: 


Edited by Ratnam, 07 February 2020 - 04:44 PM.




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