Is Cold Storage a CCP for Shelf-Stable RTE Sliced Meat?

Hello everyone, 

referring to HACCP plan for slicing Not Heat Treated/Heat Treated Shelf stable products (Salami, prosciutto crudo, coppa) the cold storage (both after receiving and after slicing)  can't be a CCP, right? I mean, this is the shelf stable definition for a shelf stable product: FSIS does not require shelf stable products to be frozen or refrigerated for food safety purposes.

that really depends on your particular product.........................

do you gain any shelf life with cold storage?  are you using the cooler to extend shelf and/or prevent Y&M growth on the surface?  How is your product packed?

Hi,

the facility will only slice log. We don't produce them. Only slicing facility of salami, prosciutto crudo, cooked ham, dry cured shoulder, pork loin in belly. But i'm oly referring to Shelf stable products (salami, prosciutto crudo, coppa)

Incoming Products are vacuum packed. Finished products are MAP packed/vacuum packed. 

What do you mean with "gain any shelf life with cold storage" and Y&M? They're shelf stable so, theorically, they don't need refrigeration to be stored safely. 

From my point of view cold storage (both for incoming products and finished products) has not to be a CCP because they're shelf stable. Y&M will not growth because of Oxygen is absent.

But this is my point of view, I used to work in a facility in Italy and I just moved to the US and I'm still trying to figure out how things work here.

Thank you

Shelf stable cold cuts terrify me.  How are you controlling for Listeria monocytogenes?  Yes the hams, salamis etc may have been matured in warmer temperatures but the process of slicing changes the microflora and risk.  Particularly as slicing machines themselves can be sources of contamination.  Then I know we obsess about it in the UK but for life longer than 10 days you really need to be sure you're also controlling for Clostridium botulinum.

But in answer to your specific question, if products are genuinely shelf stable I see no reason why that then needs to be a CCP.

They sell ambient sliced proscutto crudo in my local Lidl in the UK.  I'm waiting for the public recall to be honest.