11 replies to this topic

[loveforfood]

Hi! The company where I work is making a product with the following steps: mixing nut paste with spices, cooking to 165 F, cooling down to 40 F, packing in small containers and freezing to be sold RTE. The finished product is always tested (micro) to be released. We are considering removing the cooking-cooling step and only mixing the paste with the spices and packing and freezing it. Are there any additional hazards that we should be considering by doing that? On the first food safety plan our CCPs were the cooking and cooling steps. Pre-ops records (ATP) and Environmental Monitoring were considered prerequisite programs. If we now remove the cooking/cooling I feel that we need to do more than ATP and EMP but not sure what additional consideration we need to have here. The COAs for the ingredients will be a CCP for receiving. Any microbiologial risks added if we are not cooking? Forgot to mention that the product has high pH and will be kept below 40 F while packing. Thank you for your help!! 

[Shazlin88]

Hi loveforfood! 

1.Do you have decision tree to determine the step of processing/ raw material can be considered as CCP? 

2.Freezing can be the your CCP too since it is the last step in your processing and it can reduced your biological hazard. 
 

[Scampi]

Please research the peanut corporation of america and salmonella before you decide to remove the cooking step, it may change your mind

[The Food Scientist]

Nuts and spices are some of the foods Salmonella love :) and Salmonella loves it when you don't kill it by HEAT.

 

So no. As Scampi said, refer to Peanut corp incident :)

 

Side note FYI: Freezing is NOT a kill step. it just puts bacteria into hibernation mode, meaning inactive and won't multiply. But as soon as you thaw it,, BOOM. so you have to have a kill step before freezing if it is RTE:)

[The Food Scientist]

Also, "high pH of product" .... curious to know how "high" is this pH of your product? 

[Scampi]

Also, "high pH of product" .... curious to know how "high" is this pH of your product? 

Exactly----we run a high pH product wash here for bacterial inactivation..........minimum of 10 PLUS min temp of 94F 

 

There's no way a nut butter is running a pH           I googled, regular peanut butter has a pH of 6.3 aka the danger zone

[loveforfood]

Hi!

 

Thank you for your quick responses. Sorry I didn't give enough information earlier. I'm aware of the Peanut Corp. "incident", that's why I have my concerns about nuts. I didn't mention that the ingredients are nut butters already heat treated by the supplier and all come with COA that includes TPC, Yeast & Mold, E. Coli, Salmonella, Listeria mono. and aflatoxin. Spices come with COA that includes TPC, Yeast & Mold, E. Coli, Salmonella, Listeria mono., Staph. aureus, B.cereus and C.perfringens. pH of the final product is 5.8-5.9. I'm still working on the HACCP for the new process, that's why I have those questions. 

 

I'm not considering the freezing a CCP. In the previous process we have the cooking ( 165 F) and cooling (below 41 F within 6 h) all together with the max. time on refrigeration before freezing written down in the Process Authority letter. Removing cooking/cooling changes everything.

 

The part that concerns me the most is that the COA from the supplier is one of the basis for the safety of the final product and although the suppliers are GFSI certified I'm still concerned. I don't know, I just want to be able to sleep well at night. 

[Scampi]

AH!  makes much more sense now 

 

I still wouldn't. The material handling that needs to occur (unless your prepared to run a high risk/high care facility) is just ripe with opportunities to introduce salmonella, or other pathogens, into your process. RTE products need to be bullet proof, and with a pH of 5.9-5.9, that's offering you essentially zero additional protection. It's only relevant now because the entire scheduled process is dependent upon your recipe. Change 1 thing, you have to change them all

 

Also, the flavour profile is going to change---you'd have to reevaluate the recipe

 

The CoA is also supposed to be on a representative sample of the lot, it still doesn't guarantee that you've received clean enough spices to be without a kill step.  

 

Can you switch to UHTP instead?  you will experience significantly less flavour loss and improve throughput day/day

 

Why exactly does the company want to change?

[Charles.C]

Hi loveff,

 

Are spices pre-treated, ie a pathogen elimination step applied ?

 

COA's for low level, zero-tolerant pathogens are likely only statistically meaningful if associated with a FDA-level sampling/analytical capability. Same comment regarding monitoring.

 

Regarding freezing/CCP, I suggest that, with a cooking step, there are at least 6 process  micro factors to evaluate -

 

(1) likelihood of existence of veg/non veg pathogen after mixing items.(eg supplier approval/monitoring)

(2) likelihood of (veg/non veg) pathogen persistence after cooking (eg T/t cook process)

(3) likelihood of contamination beforefreezing (eg GMP)

(4) likelihood of contamination during freezing (eg GMP)

(5) assuming cooking is validated for veg.species, likelihood of sig. growth of non.veg. survivors  prior to freezing (eg T/t profile)

(6) likelihood of sig. growth during freezing of any sig. defects due (1-5) (eg T/t profile)

 

Assuming cooking included, the reason why, for direct/indirect application, freezing is, IMEX, not typically a CCP is that (2) is veg. survivor validated for low likelihood,  (3,4) are well implemented, (5,6) are validated as low likelihood > low risk.

 

Assuming cooking included, the possible  existence of a non.veg. pathogen factor being carried through presumably needs to be handled via supplier approval/monitoring.

 

 

The typical conservative option is that, for raw spices, step 1 has a non-Low likelihood for occurrence of micro pathogens.

 

Without a cooking step, step (1) becomes a "critical" PRP-based evaluation (eg regarding input materials/GMP). Any high risk would then pass through the process onto the RTE/consumer.

 

PS - item specifications seem to have omitted pathogenic E.coli

[Ryan M.]

Oy vey...don't do this.  I would ONLY consider this IF your customers will have a kill step on their end AFTER they add this to their products.

 

Otherwise....you just open yourself up for too much risk.

[ebb30]

Spices are known to be pretty dirty so I would be hesitant to do this, even with CoAs. Unless they specifically state that spices are heat treated, they usually are not and lots are released based on finished product testing (which is a very tiny sample and doesn't mean the lot is safe) . Another thing you could consider is obtaining validation data from the companies supplying you with the ingredients and see if they have a documented 5 log reduction in their process. That would be something to put your mind at ease that what you're getting is truly RTE. I doubt they do, but this would be one route.

 

I would also ask, why are you testing your finished product for micro? Is the heating step validated? If you have validation data that the cooking step is sufficient to kill everything (5 log reduction), then you wouldn't necessarily need to test your finished product (unless requested by a client). Finished product testing is such a small sample that if there are pathogens in your lot, you may never find them until it's too late. 

[kingstudruler1]

just some thoughts / questions

1. Are you saying that cook step should have never been a CCP? I guess I don't see how you just remove a kill step. you mention you have a process authority letter.
was your process created by a process authority? if so why would you change it?

2. COAs and testing should never be a source of assuring food safety in my opinion.
testing a few grams is no assurance.
3. I use to work for a spice company. depending on the source and processing - they scare me.
4. I get the argument that you are blending ingredients that have already been processed. the product is low aW so not much will grow. it still makes me nervous.
5. seems to me like seeing if a nut paste company could make you a custom blend would make more sense. maybe im missing something.

fyi
salmonella becomes increasing resistant to temp as water activity decreases. nut paste is low water activity so
achieving a 5 log reduction at 165 would probably take many hours. you may have addressed this but I like to point that our because
not everyone is aware of issues with thermally processing low aw foods.