5 replies to this topic

[pmf]

Hello,

 

I need a bit of help with creating a HACCP for a new product that we have been asked to launch for a customer.

 

This is a deep fried vegan product similar to falafel and the customer requires it packed in a MAP.(02<=2%; CO2 within 24.5% - 31.5%) with 19 days shelf life. In order to control Clostridium Botulinum we have identified that the Aw must be less than 0.97. We use a handheld moisture meter and measure beginning, middle and end of each batch.

 

1) Is this in-house measurement sufficient or we have to send to external lab?

 

2) We have never done this before so I need some guidance if the Water Activity and the 0xygen and CO2 percentage must be CCPs.

 

3) Also what would be the CCP validation?

 

The product so far has cooking, cooling and metal detection as CCPs but has not been packed in MAP.

 

Many thanks in advance.

[Scampi]

1) You should be fine for verification in house, but should use an external lab for validations if you decide aW is your CCP

 

2) Since shelf life isn't a food safety issue, but a quality one, this would be a company decision, aW as a product CONTROL would be a CCP 

 

3) As mentioned above, your CCP validation would be an external lab repeating aW multiple times to ensure that each batch IS at or below your tolerance

[Charles.C]

Hello,

 

I need a bit of help with creating a HACCP for a new product that we have been asked to launch for a customer.

 

This is a deep fried vegan product similar to falafel and the customer requires it packed in a MAP.(02<=2%; CO2 within 24.5% - 31.5%) with 19 days shelf life. In order to control Clostridium Botulinum we have identified that the Aw must be less than 0.97. We use a handheld moisture meter and measure beginning, middle and end of each batch.

 

1) Is this in-house measurement sufficient or we have to send to external lab?

 

2) We have never done this before so I need some guidance if the Water Activity and the 0xygen and CO2 percentage must be CCPs.

 

3) Also what would be the CCP validation?

 

The product so far has cooking, cooling and metal detection as CCPs but has not been packed in MAP.

 

Many thanks in advance.

Hi pmf,

 

More details regarding product/process/location would assist.

 

I presume this is RTE, MAP-Packed, chilled storage.

 

How did you determine the shelf-life of 19 days ? For ROP situations the maximum shelf life although not directly appearing in the haccp plan may have critical indirect requirements (see refs/examples) below. Different locations have varying legal interpretations regarding maxima, etc

 

You are entering a sensitive product category area. There may be specific legal requirements involved regarding C.botulinum and depending on where you are. For example, IIRC, one (UK?) common situation is that chilled storage around 10  days shelf life requires no specific "Secondary" (see PPS) controls regarding C.botulinum. Otherwise detailed/ multiple factors may be involved as typically spelled out in the process description.

In-house validations require appropriate "calibration" of the instrumentation involved which often involves external activities unless internal reference standards are available.

The specific CCPs depend on haccp style / regulatory (if any) / detail of process which is unknown. Validation of CCPs (CLs) typically involves theory and preliminary testing assuming Codex logic implemented.

With the initial assumption, IMO, the Process CCPs most likely relate to the, cooking,cooling, and chilled storage conditions (also see PS below).

 

These references may assist -

 

 the-safety-and-shelf-life-of-vacuum-and-modified-atmosphere-packed-chilled-foods-with-respect-to-non-proteolytic-clostridium-botulinum_1.pdf   431.54KB   22 downloads

 FSAI industrial processing heat-chill foods.pdf   683.22KB   14 downloads

 

Examples of one possible flow chart and ccp/plan for a cook-chill-ROP system are attached below but, as noted above, the specific maximum shelf life limits (30days, 3days depending on storage temperature) given are significant and may be debatable. (The  introductory text has this caveat - <<<< Note: CCPs are dependent on the facilities process; therefore, additional CCPs may be required.>>>>>)

 

 Cook-Chill-Process-Flow-Chart.pdf   40.51KB   14 downloads

 CCPs -Cook-Chill- ROP.pdf   870.82KB   11 downloads

 

Can compare the previous example to this second, more explanatory, CCP analysis of a closely similar process but which focuses on  the shorter (3 days) shelf life tolerance.

 

 HACCP(2)-CCPs for cook chill-ROP.pdf   480.85KB   11 downloads

 

This 3rd file parallels the above and includes a hazard analysis -

 

 haccp ROP_Cook-Chill_Template.pdf   1.24MB   10 downloads

 

PS - The above examples primarily reflect the US Procedure of utilizing a Primary and Secondary barrier for Safety purposes. This (slightly old but probably still relevant) attachment IMO nicely summarizes the various US approaches and elucidates the various options / specific CCPs required -

 

 HACCP - Cooked chilled ROP, US Guidance,2010.pdf   1.57MB   9 downloads

 

PPS - JFInformation -

 

 Primary-Secondary barriers in ROP Food Packaging.pdf   329.35KB   14 downloads

Edited by Charles.C, 25 January 2022 - 10:56 AM.
edited-added

[pmf]

Many thanks for the responses .

 

We are based in the UK and the products are RTE, chilled.

 

I have seen examples of both  - having gasses concentration as a CCP and as a CP but am not sure how to justify it. 

[Scampi]

The gasses do not prevent a FOOD SAFETY hazard but a quality one used exclusively to extend shelf life, that would make it by default a CP not a CCP

 

CCP = A CCP is a point in a step or procedure at which a control is to be applied to prevent or eliminate a hazard or reduce it to an acceptable level. ... They should be used only for purposes of product safety or their use should be justified by the critical nature of the CCP.

 

To make the gas level a CCP means that step is as important as the control of botulism---which simply isn't the case

 

This doesn't mean the gas levels aren't important, but they are not a CCP  (IMHO)

[Charles.C]

Many thanks for the responses .

 

We are based in the UK and the products are RTE, chilled.

 

I have seen examples of both  - having gasses concentration as a CCP and as a CP but am not sure how to justify it. 

Hi pmf,

 

Not sure what you mean by "gasses". ROP afaik is the safety related factor..

 

The UK, ROP, situation has been discussed in several threads here,  The first ref in Post 3 is the latest stance afaik however the following file was afaik the key precursor for UK and contains an enormous amount of Global investigative data. A summary for numerous Countries is included which demonstrates/compares the various potential interpretations/control handlings.

 

Examples of UK, "Key" CCPs can be found on Pages 36,53,55,56,58, although the specific entry(s) will depend on your product/process.

 

I think you will find that the UK interpretation is analogous to USA in respect to hurdles but differs substantially in respect to refrigerator temperatures/limits for shelf lives.

 

 C.botulinum_in_VP_and_MAP foods, 2006.pdf   1.27MB   13 downloads

 

PS -  I  anticipate that the well known UK text on Chilled Foods will be authoritative on this topic.

 

PPS - overlapped previous Post.

Edited by Charles.C, 25 January 2022 - 03:36 PM.
added