8 replies to this topic

[Persian girl]

Hi guys

I am new member and also young food safety manager of the food company. I know for chilled product temperature for delivery should be less than 5 degree celsius. but I saw in some haccp plans they assumed it for fish and seafoods less than 2 degree celsius. what is the rule? because I want to review and edit company's HACCP plan and like to know your comments and ideas.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

[Slab]

I'm not that familiar with the EU seafood regs but as a general rule 5 deg C is a good control strategy for cooked and raw RTE/Non-RTE fisheries products. There are very specific concerns that would need to be addressed for less than 10k anaerobic packages, oil packed, etc., with 2 deg C being a very conservative number. Histamine (scombrotoxin) has very stringent controls which may include in transit TTI or data logging in addition to receiving temperatures. 

 

It really depends on the hazard being controlled. 

 

I've attached some control guidance from the FDA if that helps

 

 Fish-and-Fishery-Products-Hazards-and-Controls-Guidance-Chapter-13-CBOT.pdf   888.07KB   25 downloads

 Fish-and-Fishery-Products-Hazards-and-Controls-Guidance-Chapter-7-Histamine.pdf   2.09MB   18 downloads

 Appendix 4 Bacterial Pathogen Growth and Inactivation.pdf   2.08MB   25 downloads

 Hazards and Controls Guidance.pdf   4.53MB   32 downloads

[pHruit]

Fish is a long way from my area of expertise, but IIRC there is a requirement that goes beyond the "normal" more generic chilled food requirements, and comes from Regulation 853/2004. Alas it's also wonderfully vague, in that for fish products the temperature "approaching that of melting ice":

https://eur-lex.euro...055:0205:en:PDF

https://www.fsai.ie/...y_products.html

https://www.fsai.ie/...y_products.html

 

EFSA did issue some clarification on this a few years ago: https://efsa.onlinel....efsa.2015.4162

(I believe there was also a request that future legislation in this provides an *actual* temperature, to aid interpretation and enforcement...).

 

UK industry body Seafish confirms their interpretation of this is 0-2C, although the link to their guidance seems to be dead at the moment. There is a comment from them in this article on it though: https://www.thegroce.../521115.article

This same 0-2C range is also noted in Bord Iascaigh Mhara's guidance on cold chain management: http://www.bim.ie/me...for-seafood.pdf

[Charles.C]

Hi guys

I am new member and also young food safety manager of the food company. I know for chilled product temperature for delivery should be less than 5 degree celsius. but I saw in some haccp plans they assumed it for fish and seafoods less than 2 degree celsius. what is the rule? because I want to review and edit company's HACCP plan and like to know your comments and ideas.

Generally, one can find stated temperature maxima of 2, 4, 5, 7, 8, 9 degC and maybe in between also, somewhere..

 

Legally, if existent, presumably controlled by FSAI.

 

This rather nice, and lengthy, Irish text (2017) which is an operational version of pHruit's last link  implies < 4degC.

 BIM-Food-Safety-Workbook-for-Seafood-Retailers.pdf   3.25MB   25 downloads

(see Pg 39/153)

 

PS - Note that Pg 38/153 disagrees slightly with the above. Very Irish.

 

PPS - JFI, I noticed this intriguing comment on the "haccp plan" of another (draft) related (non-Irish) document -

 

If the temperature of the product lies between 7 and 9°C, you may still accept and store the products, but remember that during the re-
cooling you are in breach of the law because the products do not conform to the statutory requirement of maximum 7°C.

 European Guide to Good Practise for Food Hygiene in the Contract Catering Sector (May 2009).pdf   709.26KB   16 downloads

(Pg 34)

[Persian girl]

I appreciate 

thanks for your help

I got too much information!

[Ted S]

In the US, if you are receiving a "raw" chilled seafood product that is packaged in a reduced oxygen package, receiving temps below 5*C are NOT acceptable due to the risk of nonproteolytic C. Bot outgrowth that is a potential hazard for these type products. Most food companies purchase only pasteurized frozen seafood products for this reason. Otherwise, incoming inspection will need to be managed as a CCP in your HACCP Plan, as will the constant monitoring of your on-site refrigeration systems. In addition, cooking this type seafood requires a higher cook temperature and longer hold time as well, which will also need to be a CCP if your HACCP plan. For nonproteolytic C. Bot, the seafood must be maintained at no more than 38*F (3.3*C) throughout its life cycle, starting with your supplier, and then must be cooked to no less that 195*F for a minimum of 10 minutes.

 

Since you are new to your role, I would strongly suggest that you take a Seafood HACCP training class due to all of the potential risks associated with seafood. Taking a "standard" HACCP training class is not enough when dealing with seafood due to all of the various risks such as toxins, harvesting and growing variations (wild vs farms), processing variations (frozen immediately or kept refrigerated until consumed), etc... Handling Seafood can be one of the most risky situations if not managed properly and pro actively via a well written HACCP plan.

 

In addition, I have attached a reference page from the FDA Seafood HACCP training documentation that speaks to some of this. Hope it helps. 

[Ted S]

Sorry, here is the file I mentioned. 

[Ted S]

Let's try again!

Attached Files

•  IMG_5474.JPG   247.28KB   1 downloads

[Charles.C]

Let's try again!

Maybe this is slightly easier to read

 

 ROP.pdf   269.79KB   29 downloads