8 replies to this topic

[Aleksander Petryk]

Hey everyone,

 

II would need some guidance to make a decision as I can't find a clear, black and white answer in any of the standards. (maybe with exception to BRC which is very specific for their High Risk Area definition)

 

We are manufacturing cooked meat products, formed and then steamed or deep fried. All of them are cooked to meet the listeria kill (70°C for 2minutes or equivalent)

 

We've been asked, if we can make a product that is not fully cooked (flash fried). Where surface of the product would be heated to 180°C but it will not reach the core temperature. (size implications)

 

in your opinion, would that be permited to be packed in High Risk Area?

Taking in consideration that the followin applies:

- no other products are being produced on that line afterwards until the washdown

- product is packed directly into a box with minimal operator intervention

- product is cooled/freezed (below -5°C) within 30 minutes from leaving fryer

 

I'm planning to complete risk assessment on the process, and conduct validation tests/swabbing. The main risk I can see would be a potential cross contamination if the products breaks, exposing the "uncooked" centre to the elements...

 

What are your thoughts?

 

thank you for your input!

 

cheers

Alex

 

 

 

 

[Tony-C]

Hi Alex,

 

 

Welcome to the IFSQN forums.

 

This sounds like a bit of a nightmare to me as it will jeopardise all the layout, product flow and segregation elements that should have been put in place to manage your high-risk area.

 

You will also need to consider how exposure to raw material affects the following in the area; Personnel, Protective Clothing, Staff Facilities, Equipment and Utensils, Maintenance, Cleaning Procedures/Performance Limits, Utilities (including drains) and Waste and Waste Disposal.

 

You mentioned BRC, the BRCGS Global Standard for Food Safety Issue 9 8.1.2 Guidance states the following:

High-risk areas must be fully separated areas, with physical segregation in place between them and other parts of the facility.

Time segregation is not an acceptable alternative for high-risk areas, except for the transfer areas noted below. The location and operation of all transfer points must not compromise high-risk and low-risk segregation. For example, where raw materials or staff move into a high-risk area, consideration must be given to whether this introduces a contamination hazard; it may therefore require measures that involve:

• use of disinfection

• removal of outer packaging

• double-door ovens, blast chillers or freezers (i.e. those with a separate entrance and exit)

• controlled air flow (clause 8.2.2)

• changing the design of entrances and exits (e.g. roller lifting doors may represent a risk when raised, due to the fact they have been in contact with the floor and the difficulty in cleaning them effectively).

 

Looking at the SQF Food Safety Code: Food Manufacturing, Edition 9

Section 2.3.1.5 describes the requirements for process flow:

The process flows for all new and existing manufacturing processes shall be designed to ensure that product is manufactured according to approved product formulations and to prevent cross-contamination.

Section 11.7.1 describes the requirements for High-Risk Processes:

The processing of high-risk food shall be conducted under controlled conditions, such that sensitive areas, in which the high-risk food has undergone a “kill” step, a “food safety intervention” or is subject to post-process handling, are protected/segregated from other processes, raw materials, or staff who handle raw materials, to ensure cross-contamination is minimized.

 

The SQF Code also includes requirements for Ambient Air, Service by Dedicated Staff, Distinctive Protective Clothing, Footwear and Transfer Points for High-Risk Processes.

 

In short, I don't think it is a great idea!

 

Kind regards,

 

Tony

[Charles.C]

Hey everyone,

 

II would need some guidance to make a decision as I can't find a clear, black and white answer in any of the standards. (maybe with exception to BRC which is very specific for their High Risk Area definition)

 

We are manufacturing cooked meat products, formed and then steamed or deep fried. All of them are cooked to meet the listeria kill (70°C for 2minutes or equivalent)

 

We've been asked, if we can make a product that is not fully cooked (flash fried). Where surface of the product would be heated to 180°C but it will not reach the core temperature. (size implications)

 

in your opinion, would that be permited to be packed in High Risk Area?

Taking in consideration that the followin applies:

- no other products are being produced on that line afterwards until the washdown

- product is packed directly into a box with minimal operator intervention

- product is cooled/freezed (below -5°C) within 30 minutes from leaving fryer

 

I'm planning to complete risk assessment on the process, and conduct validation tests/swabbing. The main risk I can see would be a potential cross contamination if the products breaks, exposing the "uncooked" centre to the elements...

 

What are your thoughts?

 

thank you for your input!

 

cheers

Alex

Hi Alex,

 

Tony clearly spells out the potential problems.

 

IMEX (parallel) NRTE/RTE  (not "meat"), meeting RTE micro specs can be a challenge, particularly due to intrinsic raw material micro levels and  environmental cross-contamination through to the freezer exits. Dedicated RTE lines post-lethality were unavoidable.

 

What is the design of interface between Low-High ?

Batch Air-Blast Cooler ?

 

Will BRC auditors accept a shared situation ?

[Scampi]

FYI  Canada has essentially banned batter/coated flash fried raw poultry products (apparently the average consumer can't figure out how to cook them properly)

 

What is the storage state of your current finished goods?

[Aleksander Petryk]

Hi Alex,

 

 

Welcome to the IFSQN forums.

 

This sounds like a bit of a nightmare to me as it will jeopardise all the layout, product flow and segregation elements that should have been put in place to manage your high-risk area.

 

You will also need to consider how exposure to raw material affects the following in the area; Personnel, Protective Clothing, Staff Facilities, Equipment and Utensils, Maintenance, Cleaning Procedures/Performance Limits, Utilities (including drains) and Waste and Waste Disposal.

 

You mentioned BRC, the BRCGS Global Standard for Food Safety Issue 9 8.1.2 Guidance states the following:

High-risk areas must be fully separated areas, with physical segregation in place between them and other parts of the facility.

Time segregation is not an acceptable alternative for high-risk areas, except for the transfer areas noted below. The location and operation of all transfer points must not compromise high-risk and low-risk segregation. For example, where raw materials or staff move into a high-risk area, consideration must be given to whether this introduces a contamination hazard; it may therefore require measures that involve:

• use of disinfection

• removal of outer packaging

• double-door ovens, blast chillers or freezers (i.e. those with a separate entrance and exit)

• controlled air flow (clause 8.2.2)

• changing the design of entrances and exits (e.g. roller lifting doors may represent a risk when raised, due to the fact they have been in contact with the floor and the difficulty in cleaning them effectively).

 

Looking at the SQF Food Safety Code: Food Manufacturing, Edition 9

Section 2.3.1.5 describes the requirements for process flow:

The process flows for all new and existing manufacturing processes shall be designed to ensure that product is manufactured according to approved product formulations and to prevent cross-contamination.

Section 11.7.1 describes the requirements for High-Risk Processes:

The processing of high-risk food shall be conducted under controlled conditions, such that sensitive areas, in which the high-risk food has undergone a “kill” step, a “food safety intervention” or is subject to post-process handling, are protected/segregated from other processes, raw materials, or staff who handle raw materials, to ensure cross-contamination is minimized.

 

The SQF Code also includes requirements for Ambient Air, Service by Dedicated Staff, Distinctive Protective Clothing, Footwear and Transfer Points for High-Risk Processes.

 

In short, I don't think it is a great idea!

 

Kind regards,

 

Tony

Thank you Tony!

 

I've been reading the forum for quite some years now I admire everyone contributions here! Always a place to "go to" if I'm looking for guidance, and time has come for my first ever post :D

 

yes, I have some reservations too, but looking if there is a "can do" loophole.

We tick all the boxes for SQF high care area requirements as you've outlined for all current SKU's.

 

When I'm looking at the specifications and trying to categorize the product. Actually will come down to interpretation of what it is that we are making.

It is going to be cooked product (on the outside - still to be determined how deep), as surfaces will go through 185°C heat treatment. It will be brown, looking like a cooked meatball, then transferred through the freeze tunnels cooled down to -5°C-ish, then metal detector and then dropped into the box.

The only difference would be that the final product will not be tested for listeria/salmonella because the core of the product will not hit the temperature requirement.

 

Bases on that scenario, operators in high care will have very limited, if any, exposure to the raw materials. only in case of breakages of product on the line (I would assume).

 

or am I looking for a loophole that doesn't exist and trying convince myself that we can do that :)

[Aleksander Petryk]

Hi Alex,

 

Tony clearly spells out the potential problems.

 

IMEX (parallel) NRTE/RTE  (not "meat"), meeting RTE micro specs can be a challenge, particularly due to intrinsic raw material micro levels and  environmental cross-contamination through to the freezer exits. Dedicated RTE lines post-lethality were unavoidable.

 

What is the design of interface between Low-High ?

Batch Air-Blast Cooler ?

 

Will BRC auditors accept a shared situation ?

 

thank you Charles,

 

see my answers to your questions

 

 

What is the design of interface between Low-High ?

Whole line is basically a conveyor. Cooked end of the fryer goes into the window to High Risk area, product travels on conveyor through Freeze tunnel (IQF) and then onto metal detector and then it is dropped into the box. 

There are only two operators, one in low care - loading the formers and batterers etc, and one in High Care, packing the boxes.

It is a dedicated line to one product at the time. The only cross contamination there would be is that it shares the room with other products.

 

Will BRC auditors accept a shared situation ?

If we deem that we could make this product safely, without adverse effects on other products, that would be my final point of call just to make sure. I would like to have full risk assessment done and all arguments prepared before talking to the auditor.

 

 

cheers

Alex

[Aleksander Petryk]

FYI  Canada has essentially banned batter/coated flash fried raw poultry products (apparently the average consumer can't figure out how to cook them properly)

 

What is the storage state of your current finished goods?

 

 

yeah, that is a complete different set of issues. Common sense is not that common anymore.

 

All finished goods we make are frozen, bulk packed for further processing by our customers.

 

cheers

Alex

[Tony-C]

All finished goods we make are frozen, bulk packed for further processing by our customers.

 

cheers

Alex

 

Hi Alex,

 

One other thought, for your cooked meat products what are the instructions? is the customer effectively instructed to “cook” the products or are they likely to be defrosted and eaten?

 

If the customer is instructed to effectively cook the product again and those instructions have been validated then I see less of a problem with your “not fully cooked” product.

 

Kind regards,

 

Tony

[Charles.C]

Hi Alex,

 

Thks details.

 

This sounds like a small throughput NRTE process with minimal environmental interaction with  the HR area. (IMEX (seafood), there is usually a CCP at the battering stage for both RTE and NRTE options).

 

No weight control ?

 

Just as an extension to Tony's query which I had already assumed to be the actual situation, ie NRTE product,  IMEX the whole system will now be clasified as  Low Risk.

 

Maybe the Australian terminologies are different but in BRC lingo I suggest all the "Cares" mentioned in Post 6 should be "Risks" for the RTE case,

 

I suggest you do a test run(s) to make sure that the relevant environmental / RTE Product micro. data (eg APC, etc) for the (eventually) following  RTE product  does not jump after washdown  post NRTE processing (including, i deduce, continuous [spiral?] IQF freezer ?).

Edited by Charles.C, 09 February 2023 - 11:19 PM.
edited