Internal Temp Checks - Bakery CCP

Question - I manage a small bakery operation that makes, among other things, soft cookies. We used a food safety consultant to write our SQF plan (no one on the team is a food safety professional - we're all lay people who learned on the job), and baking is our CCP for salmonella. We currently take an internal temperature on every rack of cookies to monitor the CCP - cookies are baked at around 335 for 18 minutes, and our internal temp is usually between 200 and 220 degrees, well above the kill step of 170 degrees.

 

Hi! 

:)

This topic has been discussed here a lot - because in fact there are bakeries that do not make the baking a CCP because - to be baked the product comes well above the lethal time/temp. If it didn't it would be unsaleable. 

You might find that if you have a validation to back this up (like you do) you can remove this step as a CCP. 

But try and find similar posts on this forum, so you have something to back this up. 

 

If you have a CCP, you need complete control over it. Therefore you need to measure EVERYTHING. You can't just do spot checks. But... if it isn't a CCP, it's up to you to determine what you measure. You may for example, only monitor baking time and make sure the thermometer in the oven is calibrated for example. 

I worked at a place before where we baked soft pretzels.  We never had a CCP of temperature and used flour for the same reason AJL listed above.  Our oven operator documented the oven temp at different times during the day and we also had a study we did that showed if the oven temp was maintained at a certain rage the internal temp of the product was well above the lethal time/temp.  I would follow what AJL stated above.  There may be no need to have that as a CCP.

Yep, it's actually possible to have a HACCP plan without any CCPs. The ones I wrote for our bakery products are without CCPs- all risks are controlled by the pre requisite programs which are in place. Routines etc.
CCPs in my opinion are for kill steps (which your baking rightly is) but the main purpose of your baking is to achieve the right texture etc, and a happy by product of that is killing Salmonella and E.coli. 🌞
Sounds like you all have a great understanding of your process. Our HACCP team is also people who just had sort of on the job experience - but all the better I say. They have a great understanding of the risks involved in the process.
Good luck 🤞

I'm sure I'm missing something here, but it does not make sense to me to make SAM your CCP in you bakery at the oven/temp point.

In fact in 17 years now in SQF I have never seen that.

Most bakeries I've been in and involved with make the metal detector or x ray the CCP and SAM, EC etc are handled well before those materials enter production.

Thanks for the feedback everyone. From what I understand, we'd need to remove baking as a CCP in order to stop doing an internal temp checks. I'm honestly so nervous to mess with the HACCP/PC plan. But you think we could present our auditor with our six months of internal temp checks (showing that everything is always over the kill step) and our oven validation, and that will be enough? Feels so wild to be deviating from what our consultant prepared. 

Not all consultants are right, not even all auditors 😉

Do you send out your product on a defined frequency to test for pathogens?  When I worked for a bakery, we did at least once a year.  Always came back negative.  That may help calm your nerves a bit.

 

As AJL said, consultants are not always right, you know you facility, product and process better.  Trust your process and instincts.  Take a HACCP course, there are plenty that are on-line.  That will allow you to become more familiar with it and aid in your nervousness.

Yeah and to be honest, I understand the nervousness when downgrading from a CCP. I did it myself not that long ago with a heating process and I remember doubting myself.
Our reasons were different: not a single ingredient had a microbiological risk associated with it so we had nothing to kill off. We ended up calling it a QCP.😉
An another note, have you considered acrylamide as a chemical risk? Can be formed in the baking process. We sent off for analysis once a year.

I do wonder if in USA there is an established tradition that Baking is a CCP step. (IIRC it's also emphasised as a FSMA PC ?)

 

AIB's website seems commonly referenced as the US/CCP Baking Standard in many threads on this Forum.

 

Is it possible that  Scotty's Bakery was a (validated) Outlier. :smile:

I will do a thorough risk assessment for every step of my product (let's say cupcake). My CCP will come as a result of the risk assessment. Provided that the risk assessment is done, and internal temperature is considered to be a CCP. Then, monitoring is a mandatory part of HACCP. I will certainly follow my HACCP plan and I will record the temperature. So if your other bakeries are not monitoring and recording a CCP that you determined, is a noncompliance. 

 

However, in terms of frequency determination, I will do a statistical sampling plan. Because if you have continuous batch and multiple lines, it might cost more and be cumbersome. Thus, go for a sampling plan, identify the number of product and steps where you will have to take internal temperature. 

 

To make it easy, for internal temperature I will use thermometer or its sensors sticked in the dough during cooking. You won't have to stop your production. The recording can be done by direct observation from the thermometer in the dough during cooking phase. 

Thanks for the feedback everyone. From what I understand, we'd need to remove baking as a CCP in order to stop doing an internal temp checks. I'm honestly so nervous to mess with the HACCP/PC plan. But you think we could present our auditor with our six months of internal temp checks (showing that everything is always over the kill step) and our oven validation, and that will be enough? Feels so wild to be deviating from what our consultant prepared. 

 

The six months of data you have could itself be treated as validation of the process.  Your team could review the records you have and re-asses the risk, with the conclusion being the CCP and temperature reading being replaced with something less onerous like monthly/annual calibration of the thermostat of the oven.

Do you know what the temperature distribution in the oven is like?

 

Check the actual temperature of the oven is the one that is displayed on a regular basis.

It's a little more work, but if you can figure out the distribution of the oven temperature and take the internal temperature at the place with the lowest possible oven temperature, you can confirm that all cookies have reached the minimum temperature required without measuring the internal temp on every single cookie.

I should, and forgot to, add that the bakery factory I had worked at, after the product was baked, it was frozen.  There were heating instructions for the consumer to re-heat.  That could be a factor as to why we could be ok not having an internal baking temp as a CCP.  We did do validation studies to validate that if a consumer followed the heating directions, the internal temperature would reach or surpass the temperature limit.