What Should I Do When Communicating with the USDA About Meal Validations?

Hello,

I am new to posting here, and a new FSQA Manager. Have been reading the forms for a few years  :smile:. 

Recently, I have been going back and forth with our USDA Inspector about validations for some meals we produce. They are RTE microwaveable frozen meals. He has been requiring us to do weekly tests on the items, to verify cooking temps. For obvious reasons, this really isn't practical. 

So, I did a validation report, which included 3 sets of temps, from each item, from 3 different spots on the products. I also included relevant information, like products, wattage on the microwave, etc. The meats we use for the items are also pre-cooked, the heating is for the veggies and pasta and such. All items were validated at 170+ at 6 mins, and our cooking instructions say "microwave on high 4-8 mins to cook thoroughly to 165 F"

He is stating that I need to use a lower voltage microwave, for the validation. My question is, since the meat is already pre-cooked, does he even have a leg to stand on? From what I understand, cooking instructions are for not precooked meat. Am I incorrect in my assumption? Should I use a lower watt microwave and redo all the items again?

Any advice appreciated. 

From his perspective, it looks like it is more of a quality issue than safety. But I would do a lower voltage as well just for the heck of it to see if your temp still falls within that range. 

Is he specifying a wattage of microwave you should be testing your cooking times to?

Is he specifying a wattage of microwave you should be testing your cooking times to?

No, he stated the lowest one I could find.

The issue is, we have all 1500 watt microwaves here. We would have to buy another Microwave, make another 120ish meals, and spend all that time testing it again. We are a very small plant, with like 15 people. 

I'm sorry, I just don't see how he can tell us which equipment to use, with the meat being precooked. 

Then specify in cooking instruction - "microwave (at least 1500 W) on high 4-8 mins to cook thoroughly to 165 F ". Then it is common sense that lower W microwaves require longer times.  

Your inspector is asking you to do this because if frozen food is left too long to thaw and is not heated properly, it can potentially start growing harmful microbes (even in precooked). 

The fact that the meat is pre cooked is actually a moot point, it could very easily still be or get re-contaminated at any step prior to packaging either at your suppliers factory or yours.  

That is why he is requesting this be done again-which is actually smart , you need to ensure that the lowest wattage microwave available is still capable of meeting your declaration for time and temperature-and you should want this too

 

Then it becomes an actual validation study, that you would only have to verify once/year for each item on the lowest available microwave wattage 

Can a Mod please delete this? I hit Enter and it posted before my reply was typed.

Thanks

The fact that the meat is pre cooked is actually a moot point, it could very easily still be or get re-contaminated at any step prior to packaging either at your suppliers factory or yours.  

That is why he is requesting this be done again-which is actually smart , you need to ensure that the lowest wattage microwave available is still capable of meeting your declaration for time and temperature-and you should want this too

 

Then it becomes an actual validation study, that you would only have to verify once/year for each item on the lowest available microwave wattage 

This. Thank you for breaking it down. 

I think your inspector is correct to push in this case.  I'm curious why you've got a 6-minute validation but included the directions "4-8 minutes" on the product?  Do you have any data about what temps are achieved at 4 minutes?  They've got a fair point that you might not know that instruction is sufficient, and we all know our consumers temp abuse our finished goods.  Lotta years ago a guy unsuccessfully sued a tv dinner company: he got sick because he would leave his frozen dinner on the dash of his work truck all morning to be warm when lunch time came around.  So pre-cooked items incorrectly reheated absolutely can cause illness.

One of my current plants had a recall forced by USDA for unclear instructions.  We had a cooked meat product that we add cheese to in the tray and ship out refrigerated.  Cheese and meat both are RTE at time of packaging, but for food safety we specify on the package the cook time plus the advisory to heat to 165F.  However, on the front of the package, marketing had labeled it "Heat and Serve!" which USDA said was too ambiguous since the back states the product must be heated to 165F.  So, product was recalled, and now all of the packages state "Cook and Serve" on the front.

I think your inspector is correct to push in this case.  I'm curious why you've got a 6-minute validation but included the directions "4-8 minutes" on the product?  Do you have any data about what temps are achieved at 4 minutes?  They've got a fair point that you might not know that instruction is sufficient, and we all know our consumers temp abuse our finished goods.  Lotta years ago a guy unsuccessfully sued a tv dinner company: he got sick because he would leave his frozen dinner on the dash of his work truck all morning to be warm when lunch time came around.  So pre-cooked items incorrectly reheated absolutely can cause illness.

 

One of my current plants had a recall forced by USDA for unclear instructions.  We had a cooked meat product that we add cheese to in the tray and ship out refrigerated.  Cheese and meat both are RTE at time of packaging, but for food safety we specify on the package the cook time plus the advisory to heat to 165F.  However, on the front of the package, marketing had labeled it "Heat and Serve!" which USDA said was too ambiguous since the back states the product must be heated to 165F.  So, product was recalled, and now all of the packages state "Cook and Serve" on the front.

The "4-8 mins" was to account for the variations in microwaves, as far as I know, there isn't really anyone left who knows, and am trying to take up the food safety a notch, with out breaking the bank. Hard to do I see. 

The "4-8 mins" was to account for the variations in microwaves, as far as I know, there isn't really anyone left who knows, and am trying to take up the food safety a notch, with out breaking the bank. Hard to do I see. 

I see little asterisks next to the microwave time recommendations on a lot of the packaged foods I buy.  Normally it leads to a little footnote at the bottom that says something like "**Time estimated using a 1200-watt microwave, adjust cook time to achieve 165F."

In your case, unless there are more times indicated in your study, you have no data to support a 4-minute cook time.  It's all about what you can prove in a validation, and the way you've described it, you can prove 170F+ at 6 minutes.  Unfortunately, I don't think you can reasonably extrapolate that it hit the minimum temp at 4 minutes in any microwave.

I see little asterisks next to the microwave time recommendations on a lot of the packaged foods I buy.  Normally it leads to a little footnote at the bottom that says something like "**Time estimated using a 1200-watt microwave, adjust cook time to achieve 165F."

 

In your case, unless there are more times indicated in your study, you have no data to support a 4-minute cook time.  It's all about what you can prove in a validation, and the way you've described it, you can prove 170F+ at 6 minutes.  Unfortunately, I don't think you can reasonably extrapolate that it hit the minimum temp at 4 minutes in any microwave.

So, it would be ok to put something like, "Cook to an internal temperature of 165F+, 6 minutes on High, on a 1500watt Microwave. Adjust times accordingly.". Do you think that would be acceptable?