6 replies to this topic

[dzabhi]

Hello

We have been challenged a lot recently on how we categorise our high risk production area, especially following the position statement in issue 8 and the inclusion in issue 9 of a requirement to categorise all cooked crustacea as high risk.

Under clause 8.1.2, the interpretation guidelines state that if the area contains any ingredients that have received a lesser kill (i.e. <6 log reduction for listeria), we should class it as high care. But then the same clause goes on to say that all cooked crustacea should be high risk.

This does present a contradiction for us because we do produce products that contain both cooked crustacea and other ingredients that have received a lesser kill – an example would be Prawn Cocktails. What should the area be classed as?

 

The standard is telling us to do 2 different things and I’m conscious the confusion will lead to an issue in a future audit.

 

Any help would be appreciated.
Thanks

Danny

[Dorothy87]

hi :) 

 

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 because:

 

• finished product is chilled or frozen to preserve food safety

• all components have received a full cook (equivalent to a 6 log reduction in Listeria monocytogenes)

• finished product is vulnerable to growth of pathogens or survival of pathogens that could subsequently grow during normal storage and use

• finished product is ready to eat or ready to heat or, on the basis of known consumer use, is likely to be eaten without adequate cooking.

 

page 270 - Example of Cooked crustacea, then below is high care for partially heating a crustacean (less than a 6-log reduction)  

 

I would check the log reduction for both, but usually you should go for the worst case scenario

[dzabhi]

Thank you for your response.

I've studied the wording that you have referenced. My confusion is borne from the fact that the standard stipulates that cooked crustacea should be high risk but that if any ingredient that has received a lesser kill is used in the same area, then it should be classed as high care - I see this as a contradiction for producers handling cooked crustacea as well as ingredients such as sauces, marinades and other added value (non-thermally processed) ingredients.

We handle both types of ingredients.

Some auditors (including BRC) have indicated that the area should be classed as high care but others have said high risk - we have not been able to get a consistent directive.

 

Thanks anyway for taking the time to respond.

[Martyn Sparks]

Good morning

 

I am currently facing a situation similar to Danny's.

 

Our company produces a range of ready meals and sauces in a High Care Risk Zone.

 

One of our meals is a special fried rice dish that contains cooked shrimps. The shrimps are mixed with cooked rice, proteins, and seasoning before being placed inside the retail packaging. We source the shrimps from a BRCGS certified supplier who operates in a High Care facility.

 

The second product we produce is a catering product for food service, which is King Prawns in Batter. The raw prawns are seasoned, coated in batter (Low Risk product), and then fried in a continuous fryer (exiting into our High Care Risk Zone). The product is blast frozen and packed into 2kg bulk food-grade packaging and sold to the food service sector.

 

Both products are frozen, and we provide full cooking instructions for the consumers and users.

 

After a lengthy discussion with our BRCGS Auditor regarding this clause, we were advised that despite the auditor seeking clarification from BRCGS and the Certification body, this is still a grey area.

 

I would be interested to hear how you got on with this.

 

Many thanks

 

Martyn

[GMO]

I'd argue as long as you are using the decision tree sensibly, it's going to come down to what you'd do differently. In one site I work in we use cheese for example. Cheese does not undergo thermal processing enough for a 6 log Lm reduction, much to most people's surprise. But the controls for hard cheeses are a combination of hurdles. I would argue you could describe it as either and be correct. But is it the intent of a "high care" area as defined in the standard? I don't think so. To my mind the kind of things there trying to consider are raw leaf washed into the high care zone. Not pH controlled sauces or hard cheeses where unless the site has really messed up have next to no Listeria risk.

[GMO]

I'd argue as long as you are using the decision tree sensibly, it's going to come down to what you'd do differently. In one site I work in we use cheese for example. Cheese does not undergo thermal processing enough for a 6 log Lm reduction, much to most people's surprise. But the controls for hard cheeses are a combination of hurdles. I would argue you could describe it as either and be correct. But is it the intent of a "high care" area as defined in the standard? I don't think so. To my mind the kind of things there trying to consider are raw leaf washed into the high care zone. Not pH controlled sauces or hard cheeses where unless the site has really messed up have next to no Listeria risk.

[GMO]

Apologies for the duplicate. Blooming phone!