4 replies to this topic

[ntay96]

Hi, 

 

I am still very new to HACCP and work at a small poultry company where there isn't much protocol in place (i.e., I cant look back at a previous trial for reference) 

 

We are running plant trials for 5 new marinades (tumbling chicken + marinade then packaging) for a potential new customer. The marinades contain no allergens. 

 

What are the types of things I should be thinking about? Anything I need to implement with the production staff? 

 

Most importantly is there anything I need to document to demonstrate I have full control over this trial? 

 

Thanks in advance! 

[Scampi]

What exactly are you wanting to see? 

 

I.e. marinade penetration, more tender meat, colour change  etc.

 

I would be most concerned about:

 

temperature abuse--how are you keeping the meat 7C or below during tumbling--how will you package the product

 

you need some shelf life trials if this is going to be fresh product

 

cleaning protocol for the tumbling equipment

 

Does your HACCP plan currently follow the old FSEP food safety plan?  Even though you don't have to, it's probably in your best interests to do so, particularly if you are new to the job and/or a new company  and/or looking to expand your business

 

https://inspection.c...2/1525869759693

[ntay96]

Thanks Scampi. 

 

In regards to your last point... we use the FSEP for all our prerequisite programs. I am confused about the difference between FSEP and PCP under SFCR. Can you provide a quick distinction between the two? 

[Scampi]

FSEP is a PCP but a PCP is not FSEP is the easiest way to explain

 

FSEP was designed for CFIA to perform CVS tasks against so they the 2 things align in description and scope

 

Now that FSEP is no longer auditable (ie no longer a regulatory requirement) you COULD (not that you should) drop some of the requirements out that may not apply to you and/or you'd like more flexibility in your controls

 

For example, the MMOP used to tell you how to chill carcasses post slaughter, with only 2 options, water or air (with prescribed time limits)  now it also allows for

3.4 Alternate chilling procedures

An alternate procedure may be implemented provided the chilling process is validated according to license holder's PCP which has been examined by the veterinary inspector.

Following are alternate chilling procedures which have been previously validated by the license holders:

1. Alternative times for chilling poultry carcasses, giblets, carcass parts, and salvage portions thereof to 4°C or lower.
2. Packaging of poultry carcasses, giblets, carcass parts, and salvage portions before an internal temperature of 4°C is reached. (This was me changing the rules!! I had to go all the way to National to be granted permission to prove we could do this safely)
3. Shipping of carcasses before reaching 4°C. Licence holder may ship poultry, prior to being chilled to an internal temperature of 4°C to another establishment provided that:
   • both sending and receiving establishment operate under a PCP which includes the chilling of poultry product and does not lead to any food safety hazards
   • the chilling process is continuous (including during transport) and achieves a deep muscle internal temperature of 4°C within chilling standards table
   • product is not shipped prior to achieving a surface temperature of 7°C or lower
   • the chilling process results in chilled product which complies with the Poultry Pathogen Reduction Program requirements

 

So as I said at the beginning all FSEP are PCP, but not all PCP are FSEP because FSEP lists ALL the controls you MUST have in place and a PCP from scratch allows you to decide how you'll meet the regulatory requirements

[forrest]

probably different in each country but in USA things like this are marked as experimental, not for sale. General infor can be found here Experimental and Sample Products Policy - Revision 1 | Food Safety and Inspection Service (usda.gov)