6 replies to this topic

[Foodprep]

Hello,

 

We have cooling CCP with the following limits:

 

54C to 27C in two hours or less and 54C to 4 in <7 hours. 

 

We monitor the temperature every 5 min using dataloggers. Lately, we are in the process of expansion and we are hiring a lot of new people. So, we are running into a lot of issues with datalogger use. The problem we are having is that the data is getting missed due to lack of training/understanding of new employees (I am already working on employee part). The datalogger gets turned off when it should be turned on and vice versa. Due to this, I am having big gaps in my temperature data. I will give an example below:

 

Employee inserts the datalogger in a hot product before rolling it into blast freezer (datalogger stays in) which measures at 80C at 10 am and then accidently turned it off. Another employee comes in at 1:30 pm to check the product and turned the datalogger on, the product is at 2C. I have gone from 80C to 2C in 3.5 hours.

 

Another example, Employee inserts the datalogger in a hot product which measures at 60C at 10 am and accidently pulled the datalogger out at 5C at 2 pm. Based on our freezer capacity I would easily go to 4C within the 7 hour mark but I have no physical data which shows that I met 4C.

 

Practically, I can see that we would have easily met our limits.

Theoretically, I have no data to show that.

 

I think I can use historical evidence of that product and can say that it would have met the CCP given no freezer issues. However, I am unsure if this approach can give me trouble during an audit? I am not concerned about food safety because I know we would have made the critical limits.

 

Another issue is that it has happened like 6 times in the last couple of months but the company is not able to find employees who are qualified to handle these devices. I am looking for simpler and easy to use devices. 

 

Please, I need some experienced advice on this. I am wasting too much time on this and still unsure if I am doing it right. 

[Slab]

Assuming this is RTE, what is your pathogen of concern? Hold product and evaluate total cumulative exposure based on worst case pathogen outgrowth models. Below is a a good source for this:

 

 Appendix-4--Bacterial-Pathogen-Growth-and-Inactivation-(PDF).pdf   2.08MB   6 downloads

 

Table A-1 is for considering limiting growth by medium properties, and table A-2 for cumulative time evals.

 

Of course this is for fisheries products but gives a good idea on how to evaluate these deviations. If you can't be assured of product safety by predetermined methods when a deviation occurs, then this product needs to be diverted to a non-food use, subject to post-process, or reworked.

 

As far as training... When anyone has this figured out please invite me to the chat. 

 

[Foodprep]

Thank you!!

 

Yes, RTE soups. Our pathogens of concern are C.botulinum, Listeria, C.perfringens and Bacillus. 

[GMO]

My advice is roll back...

 

How did you decide your critical limits?  Is there something which could be simpler to monitor?

 

So, for example, could you validate your blast chillers and the typical cooling curves you get (load it up to worst case scenario) so that you only need to do an "end" temperature?

 

What you're asking people to do is really complex and instinctively you know that it's not a genuine risk.  So look again at your critical limit validation.  How did you get there?  Is there something you can measure that helps you determine the food is safe without data logging each batch as you essentially are?  (Other manufacturers are safely not doing that by the way.)

[kfromNE]

We use handheld calibrated thermometers on our soups. Soups follow the USDA chilling rules. 

 

We take 3 or 4 temperatures for each soup batch. A cook, fill and chill temperature. Then maybe another chill temperature if it wasn't under 40 F or 4 C. 

 

We have a ton of data that shows our process and chill times. We have initial data and ongoing data. Monthly, we'll follow one soup and check it every hour.

This data is why we only take 3/4 temperatures for the whole cook/chill process of each batch. 

 

For new employees and a good reminder for others - we right down the steps and temperature requirements on our paperwork. 

We also use a dry erase board to keep track of when soups need to be temped after being put into the blast freezer. This is located in our dock area outside the blast freezer. This allows shipping to know what time, pallets need to be taken out. And a reminder for QC to take temperatures. Once the cooling cycle is complete and written down on the paperwork, the soup is erased from the board. 

[AZuzack]

You may want to write a decision making document about how you evaluate the data when the actual specified points are missed. I've written one for Appendix B and the USDA was fine with it.  Essentially you state that if X>130F and 40F>Y, than time from x to y is ALWAYS greater than or equal to the time from 130F to 40F (sorry, Fahrenheit when you asked in Celsius) therefore the time if the time from X to Y meets the specification, then the time requirement for 130 to 40 was met. Now it isn't a deviation to the process.  

 

I would use 2 data loggers and buy some that your employees cannot turn off.  Look into madgetechs and see if one of their devices will work. You could potentially view the data without even opening the chiller.  Madgetechs are started and stopped by someone at a computer, but most do not have a data display separate from the plugging them into the computer and using their software.  

Edited by AZuzack, 19 March 2025 - 04:55 PM.

[Foodprep]

My advice is roll back...

 

How did you decide your critical limits?  Is there something which could be simpler to monitor?

 

So, for example, could you validate your blast chillers and the typical cooling curves you get (load it up to worst case scenario) so that you only need to do an "end" temperature?

 

What you're asking people to do is really complex and instinctively you know that it's not a genuine risk.  So look again at your critical limit validation.  How did you get there?  Is there something you can measure that helps you determine the food is safe without data logging each batch as you essentially are?  (Other manufacturers are safely not doing that by the way.)

 

 

We use handheld calibrated thermometers on our soups. Soups follow the USDA chilling rules. 

 

We take 3 or 4 temperatures for each soup batch. A cook, fill and chill temperature. Then maybe another chill temperature if it wasn't under 40 F or 4 C. 

 

We have a ton of data that shows our process and chill times. We have initial data and ongoing data. Monthly, we'll follow one soup and check it every hour.

This data is why we only take 3/4 temperatures for the whole cook/chill process of each batch. 

 

For new employees and a good reminder for others - we right down the steps and temperature requirements on our paperwork. 

We also use a dry erase board to keep track of when soups need to be temped after being put into the blast freezer. This is located in our dock area outside the blast freezer. This allows shipping to know what time, pallets need to be taken out. And a reminder for QC to take temperatures. Once the cooling cycle is complete and written down on the paperwork, the soup is erased from the board. 

 

 

You may want to write a decision making document about how you evaluate the data when the actual specified points are missed. I've written one for Appendix B and the USDA was fine with it.  Essentially you state that if X>130F and 40F>Y, than time from x to y is ALWAYS greater than or equal to the time from 130F to 40F (sorry, Fahrenheit when you asked in Celsius) therefore the time if the time from X to Y meets the specification, then the time requirement for 130 to 40 was met. Now it isn't a deviation to the process.  

 

I would use 2 data loggers and buy some that your employees cannot turn off.  Look into madgetechs and see if one of their devices will work. You could potentially view the data without even opening the chiller.  Madgetechs are started and stopped by someone at a computer, but most do not have a data display separate from the plugging them into the computer and using their software.  

 

 

Great piece of advice from everyone. I gathered a bunch of ideas on how to improve this process in the future. 

 

Thank you so much for taking the time to answer my questions.

 

Kay