2 replies to this topic

[new2fs]

Hello, 

 

I am working on a new HACCP plan for a Raw, Non Intact product which is a potsticker. I am currently having some issues as the product once mechanically formed is hotter than  the rest of our products critical limit at 44.6 F.  The main issues I am having is that the since we make the dough in house, the dough stays a bit warm to help with the pliability. This then causes an issue as it goes through a mechanical forming process, which makes the filling temp which is kept cold heat up above 44.6 F. I am not able to place it into a cooler as the dough itself would dry out and needs to be shaped manually mainly due to the size. I wanted to establish my critical limit to be higher for these types of products during forming as I know we can drop down the temperature once its in cold storage pretty quickly as we will be shipping raw, frozen.   

 

I wanted to use the USDA C-27-1 Short Term Temperature Abuse article to defend my decision as a supporting document.  I also saw an article from the University of Wisconsin for critical limits for raw meat once over 41 F which was a time and temperature chart which I can probably use as well. 

 

Am I approaching this correctly? I have gotten mixed answers from our inspectors so I am a bit confused. 

 

Thank you for your advice /  help always. 

 

https://www.fsis.usd...port_FY2003.pdf

 

https://meathaccp.wi...Tables_2021.pdf

 

 

[Miti]

Are you able to drop the temperature of your filling even further? maybe frozen so it does not rise that much during the forming process? Also, consider running micro analysis prior to and after forming to demonstrate that an increase in temperature for the duration of forming does not significantly raise microbial load to make the food adulterated or lead to a loss of control of the hazard at a later stage. That could be part of justification for a higher critical limit.

[G M]

Hello, 

 

I am working on a new HACCP plan for a Raw, Non Intact product which is a potsticker. I am currently having some issues as the product once mechanically formed is hotter than  the rest of our products critical limit at 44.6 F.  The main issues I am having is that the since we make the dough in house, the dough stays a bit warm to help with the pliability. This then causes an issue as it goes through a mechanical forming process, which makes the filling temp which is kept cold heat up above 44.6 F. I am not able to place it into a cooler as the dough itself would dry out and needs to be shaped manually mainly due to the size. I wanted to establish my critical limit to be higher for these types of products during forming as I know we can drop down the temperature once its in cold storage pretty quickly as we will be shipping raw, frozen.   

 

I wanted to use the USDA C-27-1 Short Term Temperature Abuse article to defend my decision as a supporting document.  I also saw an article from the University of Wisconsin for critical limits for raw meat once over 41 F which was a time and temperature chart which I can probably use as well. 

 

Am I approaching this correctly? I have gotten mixed answers from our inspectors so I am a bit confused. 

 

Thank you for your advice /  help always. 

 

https://www.fsis.usd...port_FY2003.pdf

 

https://meathaccp.wi...Tables_2021.pdf

 

The short time references will support a validation, but they won't replace it.  The process you are performing is arguably not close enough to the exact procedures of their testing.  You have most of what you'll need, but some micro. testing on sample batches of your finished product should fill in the rest if you have a reasonably narrow set of parameters with limits established.