6 replies to this topic

[jessicamarieryan2012]

Hi there everyone,

I work with fruit pies and cream pies. I came into the job and no HARPC Hazard Analysis had been done.

 

What controls are adequate for sporeformers like C. Bot. & Bacillus Cereus? We have a baking step for the fruit pies but we don't reach a temperature high enough to destroy spores. The cream pies don't have a final kill step even though the filling and the crust are cooked separately. 

Any suggestions or advice on how to handle this on my hazard analysis. 

[Charles.C]

Hi there everyone,

I work with fruit pies and cream pies. I came into the job and no HARPC Hazard Analysis had been done.

 

What controls are adequate for sporeformers like C. Bot. & Bacillus Cereus? We have a baking step for the fruit pies but we don't reach a temperature high enough to destroy spores. The cream pies don't have a final kill step even though the filling and the crust are cooked separately. 

Any suggestions or advice on how to handle this on my hazard analysis. 

Hi jessica,

 

The 2 standard harpc resources are attached below. (Ist one esp. for baking info + typical hazards, 2nd one has detailed model  harpc hazard analysis)

 

 Draft Guidance for Industry-FDA hazard analysis,risk-based preventive controls, 01-17-2018-2.pdf   2.17MB   31 downloads

 FSPCA Preventive Controls,2016.pdf   20.75MB   36 downloads

 

Offhand -

sporeformer like Bacillus, controls - raw mat. spec./ post-baking time -temp. control / hygiene.

cream has other problems (eg see below) ?

 

These 3 random, non-harpc, threads (amongst many) may be of interest -

 

https://www.ifsqn.co...ccp-validation/

https://www.ifsqn.co...with-cream-usa/

https://www.ifsqn.co...n-lot-possible/

 

PS - there are a few other harpc presentations on this forum but, IIRC, none unfortunately for cream pies.

[jessicamarieryan2012]

Thanks Charles. I will check out those resources

[sqflady]

While I don't know about fruit and cream pies, our LACF cheese sauces control sporeformers through formulation control (moisture, pH, and salt) per our process authority and the FDA process filings.  I imagine it would be something similar for your pies.

[jessicamarieryan2012]

While I don't know about fruit and cream pies, our LACF cheese sauces control sporeformers through formulation control (moisture, pH, and salt) per our process authority and the FDA process filings.  I imagine it would be something similar for your pies.

That's what I settled on doing for our fruit pies. How did you document that in your hazard analysis and Food Safety Plan if you don't mind me asking. I wasn't sure if it was considered a process control or not

[Charles.C]

Thanks Charles. I will check out those resources

 

Apologies that my first attachment did not include the critical section - Appendix1. Added below.

 

 Draft-Guidance-for-Industry--Hazard-Analysis-and-Risk-Based-Preventive-Controls-for-Human-Food---Potential-Hazards-for-Foods-and-Processes-(Appendix-1).pdf   1.9MB   33 downloads

(1st 3 columns in Tables appear to be relevant)

 

Spore control is generally considered in 1st attachment, Pgs 124-128. Includes methods such as noted above.

 

The usual preventative options afaik involve (a) control veg. pathogen level in raw material (used IIRC for B.cereus in-wheat > flour > pastry), (b) control relevant pathogen in specific process step, eg C.botulinum, B.cereus, C.perfringens.

 

I guess the (b) question is - (i)  Is the relevant (spore) pathogen/hazard  in fruit/cream/pastry pie same/equivalent to that in cheese sauce ? (ii) is hazard in (i) significant ? (iii) if (ii) is yes, is the cheese sauce control method implementable ?.(iv) if (iii) is No, what other options ?

[sqflady]

That's what I settled on doing for our fruit pies. How did you document that in your hazard analysis and Food Safety Plan if you don't mind me asking. I wasn't sure if it was considered a process control or not

Hi Jessica,

I documented it as a Process Control in our Food Safety Plan.  Just listed it as Process Control - Formulation (pH, salt, moisture).