Is this deep fried product considered RTE?
Hi folks,
we want to produce a surimi based product, deep fried, not pasteurized and refrigerated. The packaging is consisted of a foam tray wrapped with stretchable food grade plastic. The question is: is this considered a RTE product ? and can anyone help me find resources for CCP validation? what tests are required ?
Thank you!
So your product is similar to agekama?
I'm leaning towards RTE, but you could put cooking instructions on your package if you expect customers to reheat it.
It sounds like you want to sell it unrefrigerated. (Oxford comma is throwing me here :huh: )
This is how I would start:
- Determine your CCPs- Since you are deep frying, temperature and time will likely be CCPs.
You will need to determine how much time it takes at a specific oil temperature to cook your product to 165°F or above.
Repeat multiple times and record your findings. This will validate the cooking parameters.
You'll need to verify this by taking internal product temperatures during production to ensure the minimum temp is reached.
You will also have to cool the product down before packaging. This should be done as quickly as possible.
Another CCP may be the maximum time before your product reaches the storage temperature. (ambient?)
- Shelf Life Testing- Create the product using the equipment and process you will use in the future. (Same recipe, equipment, etc.)
Package the product and send to a food testing laboratory for shelf life testing.
They will be tell you how long it remains safe and what your expiration date has to be.
The lab can also offer some suggestions for increasing shelf life.
Lowering water activity, adding preservatives, or changing packaging are some suggestions they might make.
No, that is 100% RTE as per CFIA
assuming you're using deep fry as the kill step, you need to REPEAT REPEAT REPEAT your cook step, whilst recording all the information (from the batter mixture lot # and recipe all the way to oil type/temp and cook time)
In all likelihood, your product would NOT be in the oil long enough to kill listeria or salmonella but you won't know until you try (the batter may be burnt before the internal temp is hot enough for long enough)
You would also be in the highest risk category for Listeria as per
https://inspection.c...a-monocytogenes
Sounds like you've got your work cut out for you
Like Scampi said, you'll have to do lots of trials to make sure you're reaching a temperature sufficient to kill pathogens.
If you're able to get internal temperature above 165°F, you will have at least a 5-log reduction.
Here are some references.
https://www.scienced...362028X22008742
Listeria in seafood, Table 13: Thermal Resistance of Listeria in Seafood
https://www.scienced...362028X22001272
This one shows how long different products must be cooked to kill Salmonella.
The most conservative model shows 1.2 seconds at 160°F for a 1-log reduction.
https://www.canr.msu...try_Tables1.pdf
This one shows the death curve and dwell times at multiple temperatures.
At 158°F, a 6.5-log reduction is completed instantly.
I would be more comfortable at 165°F since this temp has been validated by many studies.
Good luck! Please let us know how it works out for you. I hope your R&D goes well.
I loooooooove deep fried surimi :silly:
No, that is 100% RTE as per CFIA
assuming you're using deep fry as the kill step, you need to REPEAT REPEAT REPEAT your cook step, whilst recording all the information (from the batter mixture lot # and recipe all the way to oil type/temp and cook time)
In all likelihood, your product would NOT be in the oil long enough to kill listeria or salmonella but you won't know until you try (the batter may be burnt before the internal temp is hot enough for long enough)
You would also be in the highest risk category for Listeria as per
https://inspection.c...a-monocytogenes
Sounds like you've got your work cut out for you
Hi Scampi,
Is there a source where we can refer to as how this product type is considered RTE? CFIA inspector is looking for a C.bot test on this product however, listeria is our CCP! what is the logic for conducting c.bot test? and also it looks like we need cooking instructions for this type of product, should it be the temperature & time required to destroy listeria ? is there any refrence?
I appreciate your help and comments .
Like Scampi said, you'll have to do lots of trials to make sure you're reaching a temperature sufficient to kill pathogens.
If you're able to get internal temperature above 165°F, you will have at least a 5-log reduction.
Here are some references.
https://www.scienced...362028X22008742
Listeria in seafood, Table 13: Thermal Resistance of Listeria in Seafood
https://www.scienced...362028X22001272
This one shows how long different products must be cooked to kill Salmonella.
The most conservative model shows 1.2 seconds at 160°F for a 1-log reduction.
https://www.canr.msu...try_Tables1.pdf
This one shows the death curve and dwell times at multiple temperatures.
At 158°F, a 6.5-log reduction is completed instantly.
I would be more comfortable at 165°F since this temp has been validated by many studies.
Good luck! Please let us know how it works out for you. I hope your R&D goes well.
I loooooooove deep fried surimi :silly:
Hi Alton. thanks for all the validation steps you suggested and also references that you provided. I will definitely let you know the results but also do you have any comments on why CFIA is looking into c.bot testing while our CCP is for Listeria? I appreciate your help and comments .
Here you are
https://www.canada.c...moked-fish.html
5.1 Clostridium botulinum
Fish is most likely to be contaminated with non-proteolytic strains of C. botulinum type E (Dodds, 1993), but smoked fish, and especially multi-ingredient products containing smoked fish, may be contaminated with both proteolytic and non-proteolytic strains of C. botulinum, depending on the ingredients that are used in the formulation of the product. Therefore, the risk of botulism intoxication resulting from growth and toxin production of all possible strains of C. botulinum must be controlled (Eklund, 1993).
Inhibition of growth of the non-proteolytic strains of C. botulinum (which includes type E) is accomplished by any of the following criteria: storage temperature to be kept at less than 3°C, pH less than 5.0 or water activity less than 0.97. Inhibition of growth of proteolytic strains of C. botulinum is accomplished by any of the following criteria: storage temperature to be kept at less than 10°C, pH less than 4.6 or water activity less than 0.94 (Austin, 2001; Johnson, 2007).
I HIGHLY suggest you get yourself familiar and comfortable with what CFIA requires BEFORE you go any further
Also see:
https://www.fda.gov/...13-Download.pdf
https://www.foodsafe...ccp-violations/
do you have any comments on why CFIA is looking into c.bot testing while our CCP is for Listeria? I appreciate your help and comments .
Scampi's comment has this covered.
Here's the full download for FDA's Fish and Fishery Products. (Scampi's first link)
Here you are
https://www.canada.c...moked-fish.html
5.1 Clostridium botulinum
Fish is most likely to be contaminated with non-proteolytic strains of C. botulinum type E (Dodds, 1993), but smoked fish, and especially multi-ingredient products containing smoked fish, may be contaminated with both proteolytic and non-proteolytic strains of C. botulinum, depending on the ingredients that are used in the formulation of the product. Therefore, the risk of botulism intoxication resulting from growth and toxin production of all possible strains of C. botulinum must be controlled (Eklund, 1993).
Inhibition of growth of the non-proteolytic strains of C. botulinum (which includes type E) is accomplished by any of the following criteria: storage temperature to be kept at less than 3°C, pH less than 5.0 or water activity less than 0.97. Inhibition of growth of proteolytic strains of C. botulinum is accomplished by any of the following criteria: storage temperature to be kept at less than 10°C, pH less than 4.6 or water activity less than 0.94 (Austin, 2001; Johnson, 2007).
I HIGHLY suggest you get yourself familiar and comfortable with what CFIA requires BEFORE you go any further
Also see:
https://www.fda.gov/...13-Download.pdf
https://www.foodsafe...ccp-violations/
Thank you so much scampi. but also is there a lab for c.bot testing here in canada that you know of ? im having hard time finding one. it looks like they send the samples to U.S.
You tried BV lab and Meriuax?
Hmm. You're intending to store it chilled is that correct? If so, as long as you're not exceeding 10 days life, I see no point in validating Clostridium botulinum. If you're going for longer than 10 days life, under UK food safety "understanding", then your process would not be considered safe. If you're not cooking enough to kill Listeria monocytogenes, you won't be killing C. botulinum spores either.
But in any case, just testing it isn't going to be effective anyway. The fact it's there or not will be chance. Most of the time it won't be. But your controls need to be around cooling, chilling and shelf life (or a combination of all) for C. botulinum. There's a great training course on extending chilled shelf life (safely) beyond 10 days called SUSSLE. We are very risk averse on this in the UK though but to me it sounds kind of eek all round. But probably mostly on Lm.
Here is some guidelines on C. bot from the CFA. Although as I say, I think it's not your organism of concern.
CLEAN - Non-proteolytic Clostridium botulinum shelf life guidance - 9 7 18 FINAL
Hmm. You're intending to store it chilled is that correct? If so, as long as you're not exceeding 10 days life, I see no point in validating Clostridium botulinum. If you're going for longer than 10 days life, under UK food safety "understanding", then your process would not be considered safe. If you're not cooking enough to kill Listeria monocytogenes, you won't be killing C. botulinum spores either.
But in any case, just testing it isn't going to be effective anyway. The fact it's there or not will be chance. Most of the time it won't be. But your controls need to be around cooling, chilling and shelf life (or a combination of all) for C. botulinum. There's a great training course on extending chilled shelf life (safely) beyond 10 days called SUSSLE. We are very risk averse on this in the UK though but to me it sounds kind of eek all round. But probably mostly on Lm.
Here is some guidelines on C. bot from the CFA. Although as I say, I think it's not your organism of concern.
CLEAN - Non-proteolytic Clostridium botulinum shelf life guidance - 9 7 18 FINAL
CFIA will dictate the pathogen of concern ----what they say goes in Canada It's firm and final
CFIA will dictate the pathogen of concern ----what they say goes in Canada It's firm and final
Fair enough. Do they also dictate it needs to be tested for or can it be validated in other ways? I.e. through hurdle factors including life and chill, pH if relevant etc?