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Cooking pasta without CCP

CCP HACCP Pasta

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#1 Sousa

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Posted 08 April 2021 - 11:27 PM

Hello, I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. They produce RTE salads and use the pasta for the salads. We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking. I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens. Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right? So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier? Thank you!



#2 Charles.C

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Posted 09 April 2021 - 01:45 AM

Hello,

 

I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. 

 

They produce RTE salads and use the pasta for the salads.

 

We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking.

 

I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens.

 

Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right?

 

So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier?

 

Thank you!

 

Hi Sousa,

 

Yr query is a little confusing.

 

Why do you cook yr pasta for NRTE meals ? (I anticipate it is labelled as RTC ?)


Kind Regards,

 

Charles.C


#3 Sousa

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Posted 09 April 2021 - 02:18 AM

Hello Charles,

 

Yes you're right, I ended up mixing up things a little bit.

 

We cook and have a CCP for our pasta because we store it under refrigeration for as long as 4 days before using it in meals. Also, the pasta is used as a side, like spaghetti with meat balls. It's like those quick meals you see on Walmart. So it needs to be cooked first otherwise it would be hard dry pasta.

 

My question is, do they need a CCP for their pasta?

 

Their salads are RTE.

 

PS: Yes, they're ready to cook!


Edited by Sousa, 09 April 2021 - 02:21 AM.


#4 Charles.C

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Posted 09 April 2021 - 02:45 AM

Hello Charles,

 

Yes you're right, I ended up mixing up things a little bit.

 

We cook and have a CCP for our pasta because we store it under refrigeration for as long as 4 days before using it in meals. Also, the pasta is used as a side, like spaghetti with meat balls. It's like those quick meals you see on Walmart. So it needs to be cooked first otherwise it would be hard dry pasta.

 

My question is, do they need a CCP for their pasta?

 

Their salads are RTE.

 

PS: Yes, they're ready to cook!

 

Hi Sousa,

 

Thks the info.

 

I am not a pasta expert but I would have predicted a CCP.  For an example -

 

Attached File  pasta salad.pdf   42.59KB   13 downloads

 

RTC - So it gets cooked twice. No effect on quality ?


Kind Regards,

 

Charles.C


#5 Sousa

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Posted 09 April 2021 - 03:02 AM

Thank you very much Charles!

 

The pasta is brought up to an internal temperature of 165/175 F for a short period of time. It's still very much 'al dente' when it's put into the trays. But overall, yes, it looses quality I would say. The company serves a particularly susceptible population, so our main focus is safety, not quality unfortunately.

 

Thank you very much again, I really appreciate it!!!



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#6 danya

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Posted 09 April 2021 - 10:24 AM

I think, there is no any CCP in pasta cooking. What dangerous you intend to control by cooking? If spore-forming bacteria - temperature and duration are not enough. I think in this case PP will be enough.


Edited by danya, 09 April 2021 - 10:25 AM.


#7 Charles.C

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Posted 09 April 2021 - 10:57 AM

I think, there is no any CCP in pasta cooking. What dangerous you intend to control by cooking? If spore-forming bacteria - temperature and duration are not enough. I think in this case PP will be enough.

 

Hi danya,

 

See Post 1.

 

Although I suppose the Ukrainian variety might be "special" ?


Kind Regards,

 

Charles.C


#8 kfromNE

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Posted 09 April 2021 - 01:24 PM

Hello,

 

I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. 

 

They produce RTE salads and use the pasta for the salads.

 

We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking.

 

I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens.

 

Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right?

 

So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier?

 

Thank you!

Do they boil the pasta. If so - then you know the temperature is reaching 212 and killing the relevant microorganisms. A reason they might not have it as a CCP though they should.



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#9 Sousa

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Posted 09 April 2021 - 11:38 PM

I think, there is no any CCP in pasta cooking. What dangerous you intend to control by cooking? If spore-forming bacteria - temperature and duration are not enough. I think in this case PP will be enough.

 

The microorganism/pathogens likely to occur in dry pasta are:

 

Salmonella spp.

B. cereus

S. aureus

 

Some vendors have COAs for these microorganisms, but not all of them.

 

Thank you all for your opinions and precious help!



#10 Charles.C

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Posted 10 April 2021 - 01:02 AM

The microorganism/pathogens likely to occur in dry pasta are:

 

Salmonella spp.

B. cereus

S. aureus

 

Some vendors have COAs for these microorganisms, but not all of them.

 

Thank you all for your opinions and precious help!

 

Actually the COA for the 1st item would presumaby be "Not detected" (by an appropriate sampling/analytical methodology).

The snag is that low levels of a pathogen in a lot have a low probability of detection with typical sampling levels.


Kind Regards,

 

Charles.C


#11 Sousa

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Posted 10 April 2021 - 02:06 AM

Actually the COA for the 1st item would presumaby be "Not detected" (by an appropriate sampling/analytical methodology).

The snag is that low levels of a pathogen in a lot have a low probability of detection with typical sampling levels.

 

Yes, correct! Absolutely agree, I've talked to my co-worker, in the case they present us with their supplier's COA we will say that it's not enough to ensure no pathogens are present. They still need the CCP on their end. 



#12 danya

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Posted 12 April 2021 - 02:24 PM

Hi danya,

 

See Post 1.

 

Although I suppose the Ukrainian variety might be "special" ?

Yes, there are some differences in microbiological criteria of cereals, pasta and other like it. Also, I am sorry, I can't understand real and significant way for Salmonella in pasta (if it contain potable water, flour and salt off course :) )


Edited by danya, 12 April 2021 - 02:30 PM.


#13 Charles.C

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Posted 12 April 2021 - 02:40 PM

Yes, there are some differences in microbiological criteria of cereals, pasta and other like it. Also, I am sorry, I can't understand real and significant way for Salmonella in pasta (if it contain potable water, flour and salt off course :) )

 

Hi danya,

 

Analogous problem to people getting ill from licking cake dough perhaps ?


Kind Regards,

 

Charles.C


#14 FSQA MKE

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Posted 24 April 2021 - 09:26 PM

Hello, I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. They produce RTE salads and use the pasta for the salads. We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking. I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens. Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right? So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier? Thank you!

 

Please do not rely so heavily on this guidance document. This is not a regulation and not applicable to every operation. It is possible to have an operation that has no CCPs. A lack of CCPs does not consider products unsafe. A CCP is not a requirement necessarily.


Providing solutions for food manufacturing companies in achieving regulatory compliance, GFSI standard implementation, environmental monitoring solutions, and HACCP development.

foodsafety@email.com

https://foodsafetymuse.com

 


#15 Charles.C

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Posted 26 April 2021 - 08:31 AM

Please do not rely so heavily on this guidance document. This is not a regulation and not applicable to every operation. It is possible to have an operation that has no CCPs. A lack of CCPs does not consider products unsafe. A CCP is not a requirement necessarily.

 

Hi FSQA,

 

Sometimes the customer has to be right. :smile:


Kind Regards,

 

Charles.C


#16 FSQA MKE

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Posted 26 April 2021 - 12:43 PM

Charles,
Perhaps. & sometimes you've got to let the customer go.


Providing solutions for food manufacturing companies in achieving regulatory compliance, GFSI standard implementation, environmental monitoring solutions, and HACCP development.

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