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Is the risk of crab shell a CCP?

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Cherrypie68

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Posted 18 April 2022 - 07:13 PM

Is the risk of crab shell in picked crab meat a CCP if there is a disclaimer on the label stating it "may contain"

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Charles.C

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Posted 18 April 2022 - 10:58 PM

Is the risk of crab shell in picked crab meat a CCP if there is a disclaimer on the label stating it "may contain"

Thanks

Hi charlotte,

 

No idea regarding any specific UK Regulations, Pro or Con.

 

From a HACCP POV, probably not a CCP if you follow the US "safety" logic unless the label has a contrary text.  See enclosed extract.

 

Attached File  FDA Hard or Sharp Foreign Objects.pdf   112.26KB   11 downloads


Kind Regards,

 

Charles.C


Miss Frankie

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Posted 19 April 2022 - 04:10 PM

I worked in crab processing for over 35 years.  We never considered crab shell as a CCP
We also froze fresh clams that came to us vac packed.  When taking temps, I observed shells in some packs.  It was never an issue.

But, "may contain" is a good idea.



Cherrypie68

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Posted 20 April 2022 - 06:44 PM

Miss Frankie - you may be abe to help with another question....

If cooking of crabs and lobsters is carried out correctly, which is a CCP - is blast chilling also a CCP when any potential microbes will have been killed during the cooking process? No spore formers associted with the crabs/lobsters - cooking for 27mins at 99.5-101oC - Im getting confused as to why blast chilling the whole crabs/lobsters would be a CCP

Any thoughts?

Thanks



Miss Frankie

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Posted 20 April 2022 - 06:52 PM

Miss Frankie - you may be abe to help with another question....

If cooking of crabs and lobsters is carried out correctly, which is a CCP - is blast chilling also a CCP when any potential microbes will have been killed during the cooking process? No spore formers associted with the crabs/lobsters - cooking for 27mins at 99.5-101oC - Im getting confused as to why blast chilling the whole crabs/lobsters would be a CCP

Any thoughts?

Thanks

I can't help with that.  Everything we worked on came to us frozen. I worked for a custom processor.  Our customers would purchase the crab (mostly King), ship it to us in bulk cases and we would do further processing on it.  (I actually created a youtube video to show customers a couple years ago)



Charles.C

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Posted 21 April 2022 - 03:23 AM

Miss Frankie - you may be abe to help with another question....

If cooking of crabs and lobsters is carried out correctly, which is a CCP - is blast chilling also a CCP when any potential microbes will have been killed during the cooking process? No spore formers associted with the crabs/lobsters - cooking for 27mins at 99.5-101oC - Im getting confused as to why blast chilling the whole crabs/lobsters would be a CCP

Any thoughts?

Thanks

Please avoid duplicate posts. It causes confusion.

https://www.ifsqn.co...blast-chilling/


Kind Regards,

 

Charles.C


Philip Jones

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Posted 21 April 2022 - 01:11 PM

Hi Charlotte,

Just a disclaimer to start - I have no specific experience of seafood, so this answer is one of CCP generalities which seem to me to be relevant to your question.

 

1. In order for something to be a CCP you have to be able to set a critical limit. I note the FDA document supplied by Charles and a critical limit of 7mm may be applicable, but the cosequential follow on is that you have to have a detection/control method which allows corrective action if a 7mm+ piece of shell is found.  A CCP infers that procedures are such that no 7mm+ shell escapes detection and removal.

 

2. In my view, and therefore open to debate, regarding the "may conntain" declaration, I offer the following for consideration.

The "may contain" is a consumer warning which is distinct from your HACCP.  As a parallel example, would putting a "may kill you" label on a rifle negate the need for controls on the gun and ammunition (the equivalent of the CCP)?  Obviously not, hence my conclusion that the CCP and label are separate considerations.

 

Hope that gives a different line of reasoning. 



Cherrypie68

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Posted 21 April 2022 - 04:11 PM

Thanks for the views - it's tricky I know and I sometimes over-think these things without actually arriving at an answer.

I'm thinkng not a CCP right now.

;)

 

Apols for the duplication!



Charles.C

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Posted 21 April 2022 - 11:52 PM

Hi Charlotte,

Just a disclaimer to start - I have no specific experience of seafood, so this answer is one of CCP generalities which seem to me to be relevant to your question.

 

1. In order for something to be a CCP you have to be able to set a critical limit. I note the FDA document supplied by Charles and a critical limit of 7mm may be applicable, but the cosequential follow on is that you have to have a detection/control method which allows corrective action if a 7mm+ piece of shell is found.  A CCP infers that procedures are such that no 7mm+ shell escapes detection and removal.

 

2. In my view, and therefore open to debate, regarding the "may conntain" declaration, I offer the following for consideration.

The "may contain" is a consumer warning which is distinct from your HACCP.  As a parallel example, would putting a "may kill you" label on a rifle negate the need for controls on the gun and ammunition (the equivalent of the CCP)?  Obviously not, hence my conclusion that the CCP and label are separate considerations.

 

Hope that gives a different line of reasoning. 

Hi Philip Jones,

 

Thks for input.

 

Re yr "1" - Actually my posted document supported the non-existence of a CCP.

Re yr "2" - The safety (ie haccp) relevance depends on the specific "may contain". For example, in the case of allergenic items there may be a direct health significance but in the present case, as per "1" my opinion is to the contrary.


Kind Regards,

 

Charles.C




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