3 replies to this topic

[Khazard]

Morning guys,

 

Just needing some clarification on what the industry as a whole does regarding what i can only say is something so trivial and small that im almost ashamed to ask the question...

 

My local EHO has informed me that with the controls i have validated and in relation to the legislation guidance given to me, by them.

 

My product can have a shelf life of no more than 5 days. (its ready to eat smoked)

 

This is fine by me, i have proven with over 20 results that the life of the product can last up to 10 days and beyond in terms of safe. Texture and smell etc is ok up to 10 but gets iffy after which is why we set it to 5 days as well and wouldn't want to go beyond that anyways.

 

Now the EHO says " 5 days including the day of packing so P+4 however i argued that it should be P+5 as the guides and info i can find say 5 days shelf life not 5 days shelf life from day of packing/ producing...

 

I specifically refer to wording in "Shelf life of ready to eat food in relation to L. monocytogenes - Guidance for food business operators"

 

It says....

 

"Under the Regulation a RTE food or ingredient with a shelf life of less than 5 days is considered to be unable to support the growth of L. monocytogenes. However, in practice since such foods may contain ingredients that support growth of L. monocytogenes you must in these cases have evidence to demonstrate that the limit of 100 cfu/g will not be exceeded, otherwise L. monocytogenes must be absent. Key compliance advice is given in section 6."

 

It also says in a process flow table "do the final product characteristics control or prevent the growth of L.Monocytagens or is the shelf life less than 5 days? (see section 6i"

 

So in my opinion less than 5 days as mentioned twice in 2 different locations above in same document, day of production/packing then adding 5 days would be ok? Or should i go with pack day + 4? and shouldn't it matter when in the day it was produced and packed?

 

regards

 

Khazard

 

[Charles.C]

Morning guys,

 

Just needing some clarification on what the industry as a whole does regarding what i can only say is something so trivial and small that im almost ashamed to ask the question...

 

My local EHO has informed me that with the controls i have validated and in relation to the legislation guidance given to me, by them.

 

My product can have a shelf life of no more than 5 days. (its ready to eat smoked)

 

This is fine by me, i have proven with over 20 results that the life of the product can last up to 10 days and beyond in terms of safe. Texture and smell etc is ok up to 10 but gets iffy after which is why we set it to 5 days as well and wouldn't want to go beyond that anyways.

 

Now the EHO says " 5 days including the day of packing so P+4 however i argued that it should be P+5 as the guides and info i can find say 5 days shelf life not 5 days shelf life from day of packing/ producing...

 

I specifically refer to wording in "Shelf life of ready to eat food in relation to L. monocytogenes - Guidance for food business operators"

 

It says....

 

"Under the Regulation a RTE food or ingredient with a shelf life of less than 5 days is considered to be unable to support the growth of L. monocytogenes. However, in practice since such foods may contain ingredients that support growth of L. monocytogenes you must in these cases have evidence to demonstrate that the limit of 100 cfu/g will not be exceeded, otherwise L. monocytogenes must be absent. Key compliance advice is given in section 6."

 

It also says in a process flow table "do the final product characteristics control or prevent the growth of L.Monocytagens or is the shelf life less than 5 days? (see section 6i"

 

So in my opinion less than 5 days as mentioned twice in 2 different locations above in same document, day of production/packing then adding 5 days would be ok? Or should i go with pack day + 4? and shouldn't it matter when in the day it was produced and packed?

 

regards

 

Khazard

Hi Khazard,

 

I guess this is a continuation of the (nearly 1 year back) threads here detailing yr interactions with EHOs -

 

https://www.ifsqn.co...es/#entry184428

 

and here -

 

https://www.ifsqn.co...cp/#entry185040

 

I admire your determination to persevere.

 

INTRODUCTION:

Shelf-life is the period of time over which a food maintains its safety and/or quality under reasonably foreseeable conditions of distribution, storage and use.. The shelf-life of a food begins from the time the food is produced and/or packed.

 

 def. shelf-life.pdf   482.01KB   11 downloads

[Khazard]

Hi charles, sorry for the massive delayed response.....

 

Yes very determined to get this product going and im happy to say i was able to get approval after 5 yrs.

some very strict stuff around it though and i heard that a buisiness was shut down locally for doing this product without approval.

 

All sorted now though, do what they say as long as reasonable and all is good. 

 

I went with Pack day being day1, so P+4 USB. 

 

Thanks again though.

[Charles.C]

Hi charles, sorry for the massive delayed response.....

 

Yes very determined to get this product going and im happy to say i was able to get approval after 5 yrs.

some very strict stuff around it though and i heard that a buisiness was shut down locally for doing this product without approval.

 

All sorted now though, do what they say as long as reasonable and all is good. 

 

I went with Pack day being day1, so P+4 USB. 

 

Thanks again though.

As per Post 2 if I understand correctly.

 

In reality, for many (less sensitive) packed products prepared from "bulk", it's a fudge.