5 replies to this topic

[Laura982]

Hello IFSQN 

 

I am reviewing our haccp and have multiple products so created 2 process flows. First we have sweet cakes and tarts such as sponge, loaf cakes, cookies flap jack all of which I don't feel should have baking as a CCP. However we then also make egg custards. I am thinking these fall under the second flow for savoury pies and quiches which will have baking as a ccp but then based on reading old posts, failure to cook the quiche will be noted due to liquid egg being present. 

 

What are your thoughts please?

[AZuzack]

Do your Risk Analysis of each hazard.  Typically baking/cooking to a specified internal temperature is used to kill off microbes that can be present in the ingredients or environment.  Once the baking step becomes the way to control any micro growth from the earlier steps, then it is your CCP.  

 

FDA source for cookie CCPs:

https://www.fda.gov/...pter-6)-PDF.pdf

 

Previous discussion that looks applicable:

https://www.ifsqn.co...-and-high-care/

[GMO]

I'd be more inclined to suggest egg based foods are going to be CCPs but with baked products, the rule of thumb I always had was that if the point you needed to cook it to for food safety was close to the point where it would be acceptable for quality, it's probably a CCP.  For bread for example, you'd still have dough when you're well past the food safety limit.  

 

For egg based products, I suggest those temperatures are pretty close.

 

There is a famous controversy in Spain about their tortillas (not the bread, the egg based potato omelette) and how the traditional way of cooking them perhaps caused a food safety incident.

 

How to cook Spanish tortilla: Salmonella outbreak sparks national debate - BBC News

 

Some people will not reject egg products that are perhaps a little underdone.  Especially if they come from countries with vaccinated flocks.  Runny yolks in the UK are commonly eaten but when they're shown on Facebook recipe videos, the US posters are up in arms "needs more cooking!" 

 

(From the country that eats rare hamburgers... But that's another topic!)

[G M]

I would expect the heat treatment to be a CCP for all your baked goods.  Both raw flour and eggs are recognized as sources of Salmonella.  Plenty of spices can be sources of pathogens too.

 

Going to a longer time or higher temp for quality purposes doesn't make the lower minimums for safety irrelevant.  

 

 

...Runny yolks in the UK are commonly eaten but when they're shown on Facebook recipe videos, the US posters are up in arms "needs more cooking!" 

 

(From the country that eats rare hamburgers... But that's another topic!)

 

That's a bizzare annecdote.  Plenty of people eat over-easy and other soft or runny yolked eggs in the US.  Maybe they're just not the ones ranting on Facebook?

[GMO]

I would expect the heat treatment to be a CCP for all your baked goods.  Both raw flour and eggs are recognized as sources of Salmonella.  Plenty of spices can be sources of pathogens too.

 

Going to a longer time or higher temp for quality purposes doesn't make the lower minimums for safety irrelevant.  

 

 

Having done a lot of work recently on HACCP, I can tell you there is a lot more disagreement in it than you'd think.  But where I did my HACCP training, we had this exact discussion and the view was exactly that.  If your product could not exist without the temperature being FAR above the temperature where the pathogens would be killed = not a CCP.

 

The other complication with HACCP is that there are decision trees which are slightly different.  Codex could indeed lead you down the route you have said, Campden BRI version, to my mind, probably wouldn't because of Q4 (in version 5 of guideline 42, they've gone for a frankly wacky solution in v6 so even they have changed).

 

Ultimately I would defend it not being a CCP very happily and have done so in bakeries.  But it's the HACCP plan owned by the site, not by an auditor.

[GMO]

I would expect the heat treatment to be a CCP for all your baked goods.  Both raw flour and eggs are recognized as sources of Salmonella.  Plenty of spices can be sources of pathogens too.

 

Going to a longer time or higher temp for quality purposes doesn't make the lower minimums for safety irrelevant.  

 

 

I've just looked at another HACCP plan for a bread bakery for an audit in two weeks time and it doesn't have baking as a CCP.  I won't be raising it as a non conformity because the purpose of baking is not to kill pathogenic bacteria, that's kind of a happy accident.  Without baking at well above 80oC for some time, you won't have bread, you'll have some dough that wouldn't go down your production line.  No vegetative pathogen will survive the process to actually make the product packable.

 

What I will be looking at is their cooling area and their maintenance, hygiene etc of it.  It's not unheard of in some bakeries for Listeria to end up in product which isn't a big deal if you're just using bread at home, making a sandwich and eating it.  Counts are likely to be <10.  If you're making a sandwich, storing it for a couple of days in the fridge or, worse, for a few hours at room temperature, then with the water activity of some wetter fillings, that could be an issue.  Also just not best practice to have Listeria there at all anyway.

 

Then I'll also be having a good look into pest management.  It's such a common problem in bakeries with SPIs as well as rodents.  Rodents LOVE bakery ingredients.

 

I will of course spend time on their one CCP, metal detection because it's a CCP but I'll focus on the areas which aren't audited so much like validation of it, why they chose the test piece sizes they did etc because this site are audited to death.  If the standard requires me to observe a check, I will but I want to mostly understand how they've developed the process they have rather than seeing someone that they want me to see do a metal detection check (who always does it in front of auditors.  We all know the drill.)

 

Would you suggest I have the wrong prioritisation?  By making baking a CCP my thought process would be you are...  Sorry if that seems a little blunt but that's the whole point of HACCP to put our attention on the areas which are most important for food safety.  I'd say that metal detection, pest management and hygiene post baking will be more important than the baking process.  

 

Perhaps though in a way that's why FSMA has gone in a different direction as the three things I've picked out are from experience.  Their HACCP plan would suggest only one of them is a major concern.