BRCGS Risk Zones - Crustaceans

Dear All, 

I am looking for some advise please, with two different products. 

We purchase raw king prawns, which are handled in a low risk area, battered and then fried on a long continuous fryer, before exiting into our high care area. The finished product is King Prawns in Batter, Frozen, then packed into 2kg food grade bags (High Care Area). The end user are catering outlets. Full cooking instructions are provided. 

The frying process is a CCP, ensuring the product's core temperature is >76°c for 30 Seconds.

The second process is we produce Special Fried Rice, which includes cooked shrimps within the rice mix, to create the Special Fried Rice, the rice is then filled into the retail packaging and frozen, with full cooking instructions for the end user. 

So here is the question!

We have low-risk/high-care zones, we are certificated to the BRCGS Issue 9 Food Safety standards. The two products are long historical products which we have produced for many years, following the Low risk/High Care principles.

We were challenged on our recent BRCGS Audit regarding the requirements within the standard (8.1.2) within the interpretation guidelines it gives an example using Cooked crustacea - a product requiring a high-risk production zone. The guideline states "According to the definitions in Appendix 2 of the standard, cooked crustacea fit into the definition of a product requiring a high-risk production zone, the guide then gives further explanation but then finishes the paragraph by stating where a site is partially heating a crustacean (i.e, less than a 6-log reduction in Listeria mono), a high-care area will be appropriate.

So, it is my understanding, that we could reassess the king prawn in batter process, to reduce this to a less than a 6-log reduction, but I am lost as to how we can continue with the Special Fried Rice, as this product is purchased (Fully Cooked) at another site. 

The Auditor was happy with the risk assessment we have put in place but did require more justification/information within the Risk Assessments to include why we was following high care principles. 

I would greatly appreciate any comments, or ideas if anyone else has been in the situation etc. 

Many Thanks 

Martyn 

Hi Martyn,

Can I ask whether or not it would be a challenge for you to convert your current high-care area to a high-risk area instead.

It looks like all of your products fall into the high-risk category.

You are not partially cooking it if your CCP is 76C for 30 seconds. The equivalent to 70C for 2 minutes is 76C for 19 seconds which you are exceeding.

By "cooking instructions" I am guessing you mean more like re-heating instructions rather than cooking instructions. If they are re-heating then the area should be high-risk, if they are cooking instructions then the area can be low-risk.

It might be worth approaching your question differently, and seeing whether or not it would be practical to operate as a high-risk site and not a high-care site.