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Raw Meat Storage - is temperature a CCP?


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ramirezjaz

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Posted 28 January 2022 - 10:44 PM

Hello,

 

I am reaching out  in regards to USDA requirements for HACCP. I hope someone out there may have the knowledge to answer a question that seems to cause confusion for inspectors. I have been told they have not had the training to fully understand it. I have a HACCP plan for a raw meat facility with no CCP's all product is raw to be cooked by consumer. I have created a robust pre-requisite program that has control measures in place in order to keep our product safe along with annual validation of these programs with some validations being monthly. I have had no recalls, along with no complaints that have to do with pathogen concerns. Is it required for me to have my temperature as a CCP although I have a temperature storage program in place?



sjegorov

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Posted 29 January 2022 - 07:34 AM

Hi. What is your product - fresh meat or frozen? I don’t have any experience with USDA but found their guide: http://haccpalliance...ls/rawgroud.pdf If it's fresh then according to Q2, temperature is your CCP.



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Charles.C

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Posted 29 January 2022 - 08:21 AM

Hi. What is your product - fresh meat or frozen? I don’t have any experience with USDA but found their guide: http://haccpalliance...ls/rawgroud.pdf If it's fresh then according to Q2, temperature is your CCP.

Hi sjegorov,

 

Thks but this haccp source is now regarded as obsolete.

 

@ ramirezjaz,

 

Also not my area but it is possible that USDA may have a Regulatory requirement of minimum one CCP ? > Lucky Dip ?


Kind Regards,

 

Charles.C


ramirezjaz

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Posted 31 January 2022 - 06:54 PM

Hello,

 

Facility is ran with OPRP's which also cover product storage and handling along with addressing allergens and so forth.



Charles.C

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Posted 01 February 2022 - 04:31 AM

Hello,

 

Facility is ran with OPRP's which also cover product storage and handling along with addressing allergens and so forth.

This link may answer your USDA queries. Looks like the material referenced in Post 2 has now (2020) been comprehensively updated.

 

https://www.fsis.usd...-plant-guidance

(> haccp models)

 

I do not see any references to "OPRP" in the enclosed haccp Guidance. afaik this terminology is primarily associated with ISO-HACCP rather than Codex/NACMCF based formats.

 

PS- the generic model for vac. packed,raw intact beef has a packing temperature CCP but not one for storage.


Kind Regards,

 

Charles.C


Cathy

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Posted 01 February 2022 - 03:56 PM

It is somewhat rare to have an FSIS HACCP Plan with zero CCPs.  Also, FSIS has stated in the past that you cannot manage a (reasonably likely) hazard with a prerequisite program. Is this raw intact are non-intact?   My company (HACCP Consulting Group) includes several retired FSIS inspectors who can help you - let me know more or email us at info@haccpcg.com/. 


Cathy Crawford, HACCP Consulting Group
http://haccpcg.com/

Mulan1010

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Posted 01 February 2022 - 10:31 PM

From my experience FSIS-USDA highly, with lots of pressure, recommends facilities have at least one CCP in place.  If you do not have CCP then you need to have very good reasoning with strong justifiable support for why you do not have one.  If you have not seen it yet, FSIS issued an updated Guidebook in 2020 for developing a HACCP Plan that has some information that might be useful. https://www.fsis.usd...nes/2020-0008  

 

FYI - We have used HACCP Consulting Group, that Cathy shared above, a few times for consulting as well as for training.  Their prices for consulting are very reasonable and their staff is very knowledgeable and quick to respond; they have helped us out whenever we have needed an outside opinion with broader experience.  It could not hurt to at least contact them to request pricing and then decide if you think it is something that might work for you and your facility.  

 

If your organization belongs to NAMI then they are a good resource for such information as well.



ramirezjaz

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Posted 01 February 2022 - 11:38 PM

Hi sjegorov,

 

Thks but this haccp source is now regarded as obsolete.

 

@ ramirezjaz,

 

Also not my area but it is possible that USDA may have a Regulatory requirement of minimum one CCP ? > Lucky Dip ?

 

 

I have been in contact with some resources, USDA does not have a regulatory requirement for how many CCP's that is where the confusion comes to play, if you refer to there (HAV) Task in step 4 it clearly states an establishment must have prerequisites and or another program in place with sufficient data to prevent the relevant HAZARD.



Charles.C

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Posted 02 February 2022 - 03:59 AM

I have been in contact with some resources, USDA does not have a regulatory requirement for how many CCP's that is where the confusion comes to play, if you refer to there (HAV) Task in step 4 it clearly states an establishment must have prerequisites and or another program in place with sufficient data to prevent the relevant HAZARD.

Hi ramirezjaz,

 

I rather agree with yr opinion if your product/process is  similar to the 1st FSIS example (via my link in Post 5) attached below. IMO the (temperature) CCP1 suggested by FSIS is highly debatable and similarly for the (temperature) CCP2 in 2nd example. On the other hand the CCP1 related to use of organic acids looks potentially justifiable albeit no validatory evidence is shown. IIRC it was common in earlier haccp plans to see a MD present in situations like 2nd example which at that time conveniently donated at least one CCP. Current FSIS thinking seems to have changed.

 

Attached File  haccp plan raw intact beef,2021.pdf   260.35KB   24 downloads

Attached File  haccp plan raw ground beef,2020.pdf   534.97KB   23 downloads


Kind Regards,

 

Charles.C


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Scampi

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Posted 02 February 2022 - 01:27 PM

Storage probablly will not be a CCP, but the chilling process may be

 

If memory serves, you only have X hours  to chill to X temp with no increase in temperature at all during the chilling process


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Charles.C

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Posted 02 February 2022 - 02:28 PM

Storage probablly will not be a CCP, but the chilling process may be

 

If memory serves, you only have X hours  to chill to X temp with no increase in temperature at all during the chilling process

Hi Scampi,

 

It's a fact that as a post-cooking step this CCP is probably something of a slam dunk.

However, in a raw scenario, the US Fish community have done a lot of the maths in this kind of situation so as to be able to predict where the overall times become a significant risk in respect to typical pathogen growth potentials. The tolerances are quite substantial although the specific process here is unknown of course. Plus this product is going to be subsequently cooked as per OP.


Kind Regards,

 

Charles.C


Scampi

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Posted 02 February 2022 - 03:10 PM

Charles, in Canada, raw poultry (I'm most familiar with that) has time/temp requirements for chilling that MUST be met regardless of the fact that the consumer will cook it.  The time/temp requirements are to assist with slowing down the multiplication of the bacteria.  Just because there is a kill step at home, does not absolve the processing/slaughter plants of the responsibility to control the biological hazards, particularly when we're discussing meat, as the levels of e coli and salmonella can be incredibly high due to processing errors.  

 Red meat can be contaminated with BSE if farming/ante mortem practices are not followed, poultry gets infection with both ecoli and salmonella due to mechanical issues when birds are not a uniform size, I could go on and on.  Let's not forget that alot of that meat goes onto further processing, where we are now going to spread the bacteria all over that plant.

 

https://www.fsis.usd...lines/2021-0003

https://www.fsis.usd...lines/2021-0015

 

These has been incorporated by reference in Canada as they are scientifically proven to keep the bacteria levels as low as possible

17.11.4 Cooling Performance Standards for the Chilling of Carcasses and Cuts

As a general rule, refrigeration of carcasses must begin promptly after the end of carcass dressing and product must be cooled as quickly as possible.

For carcasses and cuts (primary cuts, sub-primary cuts, cuts and trims), the operator shall ensure and demonstrate in an ongoing manner that they are achieving compliance with the following cooling performance standards:

  • The cooling of carcasses and products is continuous, that is, the temperature of the carcass must be continually lowered until it reaches the standard.
  • The surface temperature of carcasses is 7°C or less within 24 hours of the end of carcass dressing.
  • After reaching a surface temperature of 7°C, the product's internal temperature must continue to go down in a continuous manner to 4°C or less. This should take place as quickly as possible and the cooling media shall be maintained at a maximum temperature of 4°C.
  • Before the product is cut, the internal temperature (warmest part) of the carcass is 7°C or less. The carcass must be chilled in such a way to make this possible.
  • Product temperature requirements are met at the time of shipping.
  •  

3.0 Chilling time and temperature standards

The rate of temperature decline will depend upon factors such as size of the bird, chilling method, amount of insulating fat, refrigeration facility, time of contact with chilling agent and amount of poultry product moving through the chilling system.

3.1 Dressed poultry carcasses

Immediately following evisceration and washing, all dressed poultry carcasses (other an air chilled) must be continuously chilled according to the following table:

Table 1: Water-chill standards for dressed poultry carcasses Weight of Dressed Poultry Carcasses Initial Time (hours) to Reach
≤ 14°C Table Note 1 Additional Time (hours) to Reach
≤ 6°C Table Note 1 Additional Time (hours) to Reach
≤ 4°C Table Note 1 Under 1.8 kg 2 2 4 1.8 kg to 3.6 kg 2 4 4 3.6 kg to 5 kg 2 6 4 5 kg to 7 kg 2 8 4 7 kg to 12 kg 2 10 4 Over 12 kg 2 Table Note 2 10 6

Table Notes

Table note 1

internal temperature.

Return to table note 1 referrer

Table Note 2

in this weight category, the temperature to reach within the first 2 hours is ≤ 16°C

Return to table note 2 referrer

Note:

  • As continuous chilling process has several steps, the license holder must ensure that chilling method does not contribute to increase in temperature limits allowed for each weight category in the water-chill standards table.
  • The water chilling process may be momentarily interrupted provided:
    • the interruption of chilling for each step must not result in temperature increase of the carcasses (temperature may plateau)
    • must not lead to any food safety hazards

3.2 Giblets, carcass parts and salvaged portions

Immediately following evisceration and washing, all giblets, dressed poultry parts and salvaged portions (other than air chilled) must be continuously chilled according to the following table:

Table 2: Water-chill standards for giblets, carcass parts and salvaged portions Name Time to Reach (hours) ≤ 4°C Table Note 3 Giblets (heart, liver and gizzard) 2 Table Note 4 Carcass parts (all birds except turkey) 2 Carcass parts (turkey) 4 Salvaged portions (all birds except turkey) 2 Salvaged portions (turkey) 4 Edible feet 4

Table Notes

Table Note 3

Internal temperature

Return to table note 3 referrer

Table Note 4

The foie gras liver may be chilled to 4°C in longer than 2 hours' time provided the licence holder validates the chilling process and resulting product for food safety and suitability.

Return to table note 4 referrer

3.3 Air chilling time standards

Unlike water chilling, there are no time requirements to meet the internal temperature of 4°C or lower as long as the chilling process is continuous and air chill room temperature is maintained at 4°C or lower. This is because the pathogens would be confined to surface and due to absence of water; the pathogens are not expected to permeate into the meat.

The time to air chill for carcasses, giblets, carcass parts and salvaged portions should be parts of the licence holder's PCP, must be validated for each poultry product and must not lead to any food safety hazards.

The air chilling process may be momentarily interrupted provided:

  • the product must have reached 10°C or less
  • the interruption of chilling for each step must not result in temperature increase of the carcasses (temperature may plateau)
  • the chilling protocol be validated and must not lead to any food safety hazards

Table 3: Air chill standards for carcasses, giblets, carcass parts and salvaged portions Name Time to Reach (hours) ≤ 4°C Table Note 5 Carcasses (all) Continuous chilling Table Note 6 Giblets (all) Continuous chilling Table Note 6 Carcass parts (all) Continuous chilling Table Note 6 Salvaged portions (all) Continuous chilling Table Note 6

Table Notes

Table Note 5

Internal temperature

 

 


Edited by Scampi, 02 February 2022 - 03:14 PM.

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Charles.C

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Posted 02 February 2022 - 03:11 PM

addendum -

 

I just noticed that one scenario in example attached in previous post assumes vac.packed. Strangely there is no mention in example of C.botulinum which may be relevant for chilled goods.

 

@ Scampi - Thks for the Canadian details-impressively studied. Yes, IIRC for meat, the usual logic is often that times/temperatures are calculated so as to prevent exceeding a pre-determined theoretical increase of a representative bacterium. Not on a strictly safety-based logic.

I don't know about Canada but despite, afaik, similarly elaborate precautions, the chicken meat, eg breasts, sold at retail in Supermarkets in many locations  is notorious for levels of Salmonella contamination.


Kind Regards,

 

Charles.C


Scampi

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Posted 02 February 2022 - 04:34 PM

The USA and Canada (due to trade agreements) have a shared standard that MUST be adhered to or you cannot cross the border with your product as your Vet will no longer stamp your export certificates.  As I'm not familiar with countries specific regulations I cannot speak to that, There is also a standard for campy and e coli

 

Canada has also banned the sale of partially cooked breaded chicken as the general public cannot be trusted to read instructions and fully cook said products.  So when I saw the processor has an obligation, this is the sort of thing I am speaking too.................and it looks like the UK may not be too far behind

https://www.foodmanu...ded-raw-poultry

 

https://www.fsis.usd...ectives/10250.2

 

https://inspection.c...5/1371663913885


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