8 replies to this topic

[TheEggLady]

Hi, 

 

I Know the question on zoning has been posted a few times but I can't seem to find any definitive answers regarding a template for risk assessment of the facility.

 

We are in the process of putting up a shell egg pasteurisation plant and during our first audit, it was noted that we need to have a zoning risk assessment and that our post heat treatment steps are considered high risk. We don't agree for two reasons: The egg remains in the shell through the whole process and the eggs are still cooked at the end consumer (the pasteurised eggs are specifically designated for frying in the fast food industry). Storage of the end product is ambient.

 

In an attempt to put together a risk assessment to back up our decision, We had a look at BRC's decision trees. We put each area (e.g. pre-processing area, heat treatment area, chiller and final packaging/post heat treatment area) through the decision tree and put that on a spreadsheet. The BRC decision trees are only for the production areas so we classified the non-production areas on the basis of the definition given in the BRC guideline.

 

I was told that the decision tree was not sufficient as a risk assessment and that we need to have a assessment based on severity and likelihood. Does anyone have a template for me please?

 

Side note: The zoning assessment is for YUM.

[Evans X.]

Greetings EggLady!

 

There are two things I want to point out.

Firstly, the auditor can't and shouldn't impose the methodology he/she deems good, if you can prove that your method is working and based on scientific/ experience/ good practice data then you are all good (with a disclaimer here though since I don't know the risk assessment methodology you follow, there might be a very slim chance that its approach is wrong!!!).

Secondly, the auditor actually does have a point about treating post heat treatment as high risk, because the pasteurization process also "destroys" the calcium bonds that the shell consists of and thins this protective layer of the egg, making it more permeable to microorganisms. That's the reason that you shouldn't also store them in ambient but in cold storage. To expand a little more on this, it is a major difference between EU and US. In EU the eggs don't require to be pasteurized, thus they can be stored in ambient temperature. In US egg pasteurization is obligatory (if I recall correctly) and for the above mentioned reason it is required to be stored in cold temperatures. 

 

Hope this helps,

Regards!

[TheEggLady]

Hi Evans X,

 

Thank you for the reply. In the South African retail market, pasteurised shell eggs is a fairly new product category. Shell eggs in the SA market is almost never refrigerated (even the few heat treated or pasteurised egg brands that we find here are marketed at ambient temperatures).  

 

As I understand it the US requirement for refrigeration results from the fact that the US egg packing facilities are obliged to wash their eggs before resale which washes away the natural coating (also called a cuticle) on the egg's shell surface thereby making the egg vulnerable to penetrating bacteria. Washing of eggs is however not a requirement in the EU which enables them to store eggs at ambient temperatures (I don't live in the EU or US so please feel free to correct me if I am wrong here). 

 

By far the most common way to pasteurise eggs is to use a type of water bath method and I fully agree that this method would lead to the cuticle being washed away (in a similar manner to the washing of eggs in the US) meaning that the pores are open and penetrating bacteria can make their way through the shell pores into the contents of the egg. Our process is however a dry pasteurisation process (sorry for leaving out this vital part of info in the original post), meaning that the cuticle remains in tact and bacteria cannot easily enter the shell.

 

As far as destruction of shell calcium during the pasteurisation process, I have never heard of this but I would love to read up on this a bit, do you perhaps have any reference material to share on this topic?

 

We have scientifically validated that the salmonella reduction is sufficient and also that our equipment can heat and hold the eggs to the required temperatures. We have also done a shelf life study to confirm a shelf life of about two months (I know this could seem rather short to some, but this is regulated so we are not allowed to extend the shelf life beyond this). We also have a salmonella monitoring program in place on farm level and we are candling all the incoming eggs to ensure the eggs are not cracked, We also have visual inspections in place to ensure we do not have any heavily soiled eggs going through this process.

 

For the methodology of the risk assessment we simply listed each area on a spreadsheet, wrote out the questions to BRC's zoning decision trees and answered them until we could reach a decision. Step 3 of BRC's decision tree reads as follows: "Does the area contain products which, on the basis of cooking instructions and known customer use*, undergo full cooking** prior to consumption?" and if you answer "Yes" then the product is classified as low risk. We said yes at this step as the eggs are still going to be fried at the fast food outlet and our goal is not to provide a RTE or RTH product. 

[sqflady]

Personally, I would just document the risk assessment in the way Yum is looking for.  Sounds to me like they want you to rate the risk level based upon the likelihood of occurrence and the severity if it did occur.  You could list out your areas and rank them "low, medium, high" or use a numbering system 1-10, for example.  The results can reflect the information from your BRC decision tree process and should align.  Should be fairly simple to complete this.

[Scampi]

I work in shell eggs and have questions:

 

You've said the eggs are A) pasteurized and B) cooked   which one is it?  Those are not interchangeable terms

 

Heating the eggs for an extended period of time UNLESS rapidly cooled is going to force any salmonella from the shell surface into the egg.  Not sure how you can get the geometric middle hot enough and still have a running egg suitable for frying

 

 

P.S. I agree with BRC on this---you are producing a heat treated ambient finished goods, you need zones

[Charles.C]

Hi, 

 

I Know the question on zoning has been posted a few times but I can't seem to find any definitive answers regarding a template for risk assessment of the facility.

 

We are in the process of putting up a shell egg pasteurisation plant and during our first audit, it was noted that we need to have a zoning risk assessment and that our post heat treatment steps are considered high risk. We don't agree for two reasons: The egg remains in the shell through the whole process and the eggs are still cooked at the end consumer (the pasteurised eggs are specifically designated for frying in the fast food industry). Storage of the end product is ambient.

 

In an attempt to put together a risk assessment to back up our decision, We had a look at BRC's decision trees. We put each area (e.g. pre-processing area, heat treatment area, chiller and final packaging/post heat treatment area) through the decision tree and put that on a spreadsheet. The BRC decision trees are only for the production areas so we classified the non-production areas on the basis of the definition given in the BRC guideline.

 

I was told that the decision tree was not sufficient as a risk assessment and that we need to have a assessment based on severity and likelihood. Does anyone have a template for me please?

 

Side note: The zoning assessment is for YUM.

Hi TEL,

 

YUM/eggs not my areas of familiarity but several aspects of yr process/process risk classifications seem intuitively odd/ HACCP "illogical".

 

One obvious haccp question is why bother to use a pasteurize step if the end-user reliably eliminates any accumulated micro-contamination ?.

 

A few comments -

 

(1) As you are no doubt aware, the purpose of pasteurization is typically (logically) intended to deliver a RTE end product so that the heat step usually requires a risk-based CCP. I'm unsure how you can logically reconcile "pasteurizarion" with an NRTE end product. (also see (3)). TBH I'm surprised you can store at ambient for 2 months (also see (4)).

 

(2) There is a caveat (see asterisk *) in the previously referred BRC ambient chart which would be triggered if your product is designated as RTE . I anticipate this would ultimately give a designation of ambient high care (ie "High Risk).

 

(3) It's a tricky HACCP /hazard analysis IMO although IIRC some meat haccp Plans conveniently handle such scenarios as "Regulatory" CCPs.

It seems to me you are partially being tripped up by "terminologies". Might be easier to classify the heating step as a "blanching" similar to  heat usage in vegetable production for lowering micro./pathogen.loading. This could avoid the BRC etc RTE awkwardness.

 

(4) I'm curious how you evaluate the shelf-life, Based on Safety with respect to Salmonella ?

 

(5) As per Post 5 I presume you can Validate that end-user processing eliminates any accumulated micro.contamination ?

 

(6) The solution may also relate to YUM's specific textual requirement which is ?

 

PS - IIRC there are some previous threads on this Forum containing egg haccp plans.

[Tony-C]

Hi TheEggLady,

 

An interesting one! Be useful to know which product category you are being audited against? I presume it is category number 7 Processed food and liquids with pasteurisation ….. etc

 

I can see a case for arguing that the Pasteurised Eggs in Shells are an Enclosed Product. 

 

Regardless, any assessment needs to ensure that the intended use (of the egg being cooked by the customer) is real and there is not likely to be unintended use. For example the customer making mayonnaise with the Pasteurised Eggs in Shells when you haven't taken that into consideration in your Food Safety/HACCP assessment. I believe that question makes a difference in defining your zones.

 

Note that the Production Area Decision Trees have been omitted in Issue 9.

 

Kind regards,

 

Tony

Edited by Tony-C, 01 December 2022 - 06:25 AM.

[jfrey123]

I'm only vaguely aware of the basics regarding eggs and how the pasteurization affects the shell (basically what people have mentioned here).  But merely from the process standpoint, at some level you've already identified a risk between your raw and sellable product that requires you pasteurize the product.  Otherwise, you wouldn't be pasteurizing it.  I take it you cannot sell the raw eggs to your customers for this reason, so for this reason you've got a somewhat higher risk with finished goods than raw.  I say higher, not specifically high risk, because it sounds like you've got some science to back up your process on the ambient storage and whatnot.

 

Based on what you've said, there absolutely should be a different designation for your finished storage vs raw material storage.  When the auditor refers to a risk assessment on severity and likelihood, they're wanting to see all of your zoned areas go through some sort of matrix like the one I've attached below.  Once you identify the risks, example someone walking from raw storage directly into finished goods, you can use your data to determine the likelihood and severity of your finished goods being contaminated while in storage.

 

 

[Charles.C]

Hi TEL,

 

I was unable to locate any reference to requirements of  risk status of zoning areas in a 2013 Yum audit standard ??.

 

Perhaps yr Yum auditor was ("severity") referring to the  haccp section of the audit Standard -

 

 yum haccp program.pdf   140.04KB   164 downloads

 

Please advise/upload the relevant text in Standard.

 

PS - @ jfrey, thks attachment although the matrix example looks more oriented to something like a flood disaster situation ?