Ready-To-Cook Products in RTE Facility

Hi everyone! A customer reached out to our company regarding a potential project (RTC product) in our Packaging Facility (RTE/RTH Facility). 

I guess I'm a little lost and still trying to determine if we should treat the RTC product (frozen bread dough) as a "Raw" product .

Thank you and best regards!

Frozen, raw bread dough is definitely "raw" and will be a source of Listeria and Salmonella and to a degree, E Coli, although that does (unreliably) die slowly on freezing.  If part cooked it would be different if it's reached a sufficient temperature.  But if raw dough then yes, it shouldn't be in your RTE facility if you are needing to control pathogens, i.e. you're high risk or high care.

You could assemble it somewhere else in your plant though if it's clearly a ready to cook product.  These exist in the UK and I've worked with them quite a bit.  Generally it needs to be a line in your low risk area and you will have pathogen presence.  My advice though is that you really do need to make sure that it would be clear to a consumer that it needs fully cooking.  If it's got raw dough in that should be clear (albeit there have been issues with that in the past...)