5 replies to this topic

[ShaunD]

Hi,

 

I'm after a bit of advice regarding the attached position statement from BRCGS, specifically regarding cooked crustacea.

 

I work for a company that produces various seafood products, I understand that any cooked crustacea that has undergone a 6 log reduction in Listeria monocytogenes is considered high-risk and must be produced in a high-risk area that meats all the requirements of the standard.

 

My question is, if we produce, for example, a seafood selection that contains prawns that have received a full cook (equivalent to a 6 log reduction) and mussel meats and/or squid rings that have received a partial cook (less than a 6 log reduction), can this finished product be produced in a high-care area or do we need ensure the mussel meats and/or squid rings receive additional cooking to achieve a 6 log reduction?

 

I would assume that because 1 or more components have not received a 6 log reduction, the finished product must be classified as high-care so can therefore be produced in a high-care area.

 

I have another question that may sound a bit unusual, can a production zone be high-risk in the morning and then get down-graded to high-care in the afternoon? We have a room that is totally segregated from our low-risk area that we currently classify as high-care, could we produce high-risk products first and then go onto high-care products providing all high-risk products/raw materials were removed prior to the change-over. Once the change-over had occurred we could not go back to high-risk products without a fully validated night-shift clean before producing high-risk products the next morning. 

 

Any advice would be greatly appreciated.

[Charles.C]

Hi,

 

I'm after a bit of advice regarding the attached position statement from BRCGS, specifically regarding cooked crustacea.

 

I work for a company that produces various seafood products, I understand that any cooked crustacea that has undergone a 6 log reduction in Listeria monocytogenes is considered high-risk and must be produced in a high-risk area that meats all the requirements of the standard.

 

My question is, if we produce, for example, a seafood selection that contains prawns that have received a full cook (equivalent to a 6 log reduction) and mussel meats and/or squid rings that have received a partial cook (less than a 6 log reduction), can this finished product be produced in a high-care area or do we need ensure the mussel meats and/or squid rings receive additional cooking to achieve a 6 log reduction?

 

I would assume that because 1 or more components have not received a 6 log reduction, the finished product must be classified as high-care so can therefore be produced in a high-care area.

 

I have another question that may sound a bit unusual, can a production zone be high-risk in the morning and then get down-graded to high-care in the afternoon? We have a room that is totally segregated from our low-risk area that we currently classify as high-care, could we produce high-risk products first and then go onto high-care products providing all high-risk products/raw materials were removed prior to the change-over. Once the change-over had occurred we could not go back to high-risk products without a fully validated night-shift clean before producing high-risk products the next morning. 

 

Any advice would be greatly appreciated.

Hi Shaun,

 

Haven't studied the (unattached) position statement yet. Comments below are therefore preliminary.

 

The answers may require more product/process flow information, eg -

 

(1) are mussel/squid items categorised as RTE ?

 

(2) a high risk production area has stricter design/usage requirements than high care. Is area of interest BRC-compliant for former category ? Also your projected manouevring involves what products ?. (eg see following paragraph)

 

I have worked with similar products. For micro.reasons, mollusc production areas always dedicated/isolated from the rest and heavy decontamination procedure after finishing.

[ShaunD]

Hi Charles,

 

Thanks for the reply and sorry for the delay, had an unannounced auditor turn up yesterday.

Also, apologies for the failed attachment (had chosen the file but failed to hit the attach this file button, should be added now).

 

To answer your questions:

1: Yes, the mussels and squid items are ready to eat, the raw materials have received a thermal cook of 75°C for 15 seconds or just a minimum core temperature of 72°C (no length of time advised when asked), which is just below the 6 log reduction required for high-risk.

 

2: The area has been audited by BRC on numerous occasions and would meet all the criteria required for high-risk, have even been asked why we class it as high-care and not high-risk so have had to explain the above.

 

I understand the heavy decontamination procedure after finishing but we would have a full clean down carried out at night so the area was ready and suitable for high-risk so we would produce these products first. Once all high-risk products were complete i.e. crab meat only, we would then clear away all raw materials and finished products before switching onto the high-care mixed products therefore the product risk category has reduced with no requirement for clean down, even allergen, as crustacea is the common allergen. Once we had changed, we could then not go back to high-risk products until the next morning following a full clean.

So there has been time segregation as well as a full clean down. Weekly environmental swabbing, including listeria, is carried out to validate/verify cleaning is acceptable. 

 

I hope that makes sense?

Attached Files

•  F837.pdf   314.77KB   11 downloads

Edited by ShaunD, 22 October 2021 - 06:31 AM.

[Charles.C]

Hi Charles,

 

Thanks for the reply and sorry for the delay, had an unannounced auditor turn up yesterday.

Also, apologies for the failed attachment (had chosen the file but failed to hit the attach this file button, should be added now).

 

To answer your questions:

1: Yes, the mussels and squid items are ready to eat, the raw materials have received a thermal cook of 75°C for 15 seconds or just a minimum core temperature of 72°C (no length of time advised when asked), which is just below the 6 log reduction required for high-risk.

 

2: The area has been audited by BRC on numerous occasions and would meet all the criteria required for high-risk, have even been asked why we class it as high-care and not high-risk so have had to explain the above.

 

I understand the heavy decontamination procedure after finishing but we would have a full clean down carried out at night so the area was ready and suitable for high-risk so we would produce these products first. Once all high-risk products were complete i.e. crab meat only, we would then clear away all raw materials and finished products before switching onto the high-care mixed products therefore the product risk category has reduced with no requirement for clean down, even allergen, as crustacea is the common allergen. Once we had changed, we could then not go back to high-risk products until the next morning following a full clean.

So there has been time segregation as well as a full clean down. Weekly environmental swabbing, including listeria, is carried out to validate/verify cleaning is acceptable. 

 

I hope that makes sense?

Hi Shaun,

 

Thks attachment.

 

I previously missed this document and frankly I found the segment on cooked crustacea rather astonishing. I deduce that the document arose to support seeming semantic difficulties in the Standard as related to certain ongoing, "hybrid", operational procedures . And will apparently continue to do so. I also note that, curiously, the scope is limited to crustacea.

 

I deduce that yr entire setup could be classed as high risk except for the fact that (log reduction) process data for some items are insufficient to validate the nominal, "high risk", designation. Accordingly the classification has semantically devolved to "high care" in such instances. Very subtle.

 

In the context of yr OP query, Is there a UK Regulatory position on what quantitatively  defines the labelling of a commercialised food item to be RTE ?

 

Process-wise, in this case I would personally distinguish more between inshore mollusca and deep-sea marine species rather than high risk/care elements but only due my own (micro) experiences with (non-UK) inshore mollusca. (A question of Sourcing control).

 

Assuming Regulatory permitted, with everything else being equal, I suppose you can continue "artificially", complying with the BRC textual high risk/care differentials..

 

I note that some attention is also currently being applied to molluscan allergens.

 

Apologies and please correct me  if I have not fully understood the subtleties of yr OP.

[ShaunD]

Thanks Charles,

 

Thanks for your reply, and again, sorry for late response, yet another 2 day unannounced audit (seems all UK retailers have decided October is the month to resume unannounced audits).

As for a UK Regulatory position on what classifies as RTE, the retailers have a larger legal team and decide the category for us during the development stage.

 

If the statement had included molluscs, the situation would have been a lot easier to cover off. I am hoping there will be some clarification when BRCGS v9 is issued but until then I'll have to wait and see. I had even asked the question to our last BRCGS auditor during their last audit but was told they were not allowed to offer advice.  

 

I imagine that, no matter what we decide, individual auditors will have their own opinions so we will just have to ensure that we have sufficient justification in place before our next BRCGS audit.

 

Cheers

Shaun

[Fishlady]

I believe from personal experience that the Crustacea verbiage came from a situation in the US where some companies argued that cooked crab was not RTE because it was labeled with instructions to heat before serving. This was causing inconsistency in audits because some reprocessors of frozen cooked crab were treating their crab as low risk and others were considering it high risk. One processor who could not meet the high risk criteria blew the whistle to try to bring consistency.
Regarding switching from high risk to high care in the same area, I would suggest checking with your CB or directly with BRCGS.