5 replies to this topic

[Mrearlgrey]

Hi All,

Bit of background: I'm quality systems manager in a chicken cutting factory in the UK.

The operation is quite simple, intake of whole birds > automatic cutting > Packing. this is chilled or frozen.

For the frozen line, we use a spiral freezer where the individual chicken cuts (e.g. drumsticks) are transferred onto the freezer belt, go through the freezer equipment and come out at -18˚C after about 45min. - We work to BRCGS food.

 

I have been doing a lot of research online and on this forum, in addition to speaking with technical staff in my company, and I'm quite puzzled there isn't a clear guidance on 2 particular things: 1-what the "quick" in "quick frozen" actually means in quantifiable terms and 2- what "brief periods" mean in the legislation quoted below.

 

The legislation I am considering here is The Quick-frozen Foodstuffs (England) Regulations 2007 which states:

“quick-frozen foodstuff” means a product–

(a) comprising food which has undergone a freezing process known as “quick-freezing” whereby the zone of maximum crystallisation is crossed as rapidly as possible, depending on the type of product; and

(b) which is labelled for the purpose of placing on the market to indicate that it has undergone that process

 

 

I understand the legislation might not specify an exact amount of time, given that this does depend on the type and volume of food ("the zone of maximum crystallisation is crossed as rapidly as possible, depending on the type of product") but then how is one supposed to justify or validate that the process has been carried out "as rapidly as possible".

In my view a reference table, something like the cooking temperature/time from codex (60°C for 45 minutes / 65°C for 10 minutes / 70°C for 2 minutes / 75°C for 30 seconds / 80°C for 6 seconds etc) would be beneficial even just as a guidance.

 

For my second point the same legislation reads as follows:

 

(b) a permitted exception relating to the temperature of a food applies when—

(i) that food is kept within brief periods during transport (including local distribution)at a temperature warmer than -18°C but not warmer than -15°C,

 

How long is "brief periods"? again this is open to a variety of interpretations. 

This question actually stems from the fact that one of our suppliers of frozen vegetables, is stating that their deliveries will be at a temperature of -15°C as this is acceptable under the legislation aforementioned, which I have an issue with, because we want our frozen deliveries to be at -18°C at intake.

 

I feel like I might be the only one wondering about these topics, and that maybe I am missing something that is really basic or plain to see for others.

 

Any thoughts would be much appreciated - thank you.

 

[GMO]

I've tried the British Frozen Food Federation which you think would be helpful. 

 

Found this resource:  Guide-to-Storage-Handling.pdf

 

Not that helpful sadly.

 

If you're members they will probably have technical support which you can tap into and more technical guidance so it might be worth contacting them.  Also contact Campden.

 

I found a source online, albeit not an authoritative one stating 25-31F (-4 to -0.5oC or -1oC in some sources) were the key temperatures to minimise for IQF (presumably the zone of maximum crystallisation) and to do so the manufacturers freeze individually, not as a pack and in much lower temperatures.  I.e. you want to blast through -4 to -0.5oC as quickly as possible.  Presumably you need to check that using a datalogger.  How quick is "quick" though, I struggled to find.

 

Sorry I can't share more but if you have membership with Campden BRI, try them.  If you don't, it's worth contacting the BFFF even if you're not members to ask.  

[hakan.kahveci]

İn My Opinion ; create your own standard through validation. Your BRCGS auditor will not expect to see a reference to a government table. They will expect to see a well-documented freezing validation report that justifies your process parameters

 

You are not missing anything basic; you are dealing with the practical application of intentionally flexible legislation.

1. For Quick-Freezing: Conduct a freezing curve validation study for your key products. Use this to define and justify your freezing time parameters. This will satisfy BRCGS requirements.

2. For Delivery Temperatures: Uphold your specification of -18°C. Reject the supplier's assertion that -15°C is acceptable as a standard. Request their supporting data and risk assessment. Define in your procedures that "brief periods" during unloading are acceptable for air temperature fluctuations, but that the product core temperature must remain at or below -18°C.

This approach demonstrates due diligence, aligns with BRCGS standards, and protects the quality and safety of your product.

[Mrearlgrey]

I've tried the British Frozen Food Federation which you think would be helpful. 

 

Found this resource:  Guide-to-Storage-Handling.pdf

 

Not that helpful sadly.

 

If you're members they will probably have technical support which you can tap into and more technical guidance so it might be worth contacting them.  Also contact Campden.

 

I found a source online, albeit not an authoritative one stating 25-31F (-4 to -0.5oC or -1oC in some sources) were the key temperatures to minimise for IQF (presumably the zone of maximum crystallisation) and to do so the manufacturers freeze individually, not as a pack and in much lower temperatures.  I.e. you want to blast through -4 to -0.5oC as quickly as possible.  Presumably you need to check that using a datalogger.  How quick is "quick" though, I struggled to find.

 

Sorry I can't share more but if you have membership with Campden BRI, try them.  If you don't, it's worth contacting the BFFF even if you're not members to ask.  

Thank you GMO, I did encounter that BFFF guidance, although it just mirrors the exact wording of the legislation.

Yes Campden might be able to provide more details.

[Mrearlgrey]

İn My Opinion ; create your own standard through validation. Your BRCGS auditor will not expect to see a reference to a government table. They will expect to see a well-documented freezing validation report that justifies your process parameters

 

You are not missing anything basic; you are dealing with the practical application of intentionally flexible legislation.

1. For Quick-Freezing: Conduct a freezing curve validation study for your key products. Use this to define and justify your freezing time parameters. This will satisfy BRCGS requirements.

2. For Delivery Temperatures: Uphold your specification of -18°C. Reject the supplier's assertion that -15°C is acceptable as a standard. Request their supporting data and risk assessment. Define in your procedures that "brief periods" during unloading are acceptable for air temperature fluctuations, but that the product core temperature must remain at or below -18°C.

This approach demonstrates due diligence, aligns with BRCGS standards, and protects the quality and safety of your product.

Thank you hakan.kahveci, this is good advice.

Just to clarify, I am only seeking guidance on the legislation, rather than trying to implement or changing a system or procedure.

No auditor has questioned our process or validation records to date (in regards to this specific query).

[GMO]

Thank you GMO, I did encounter that BFFF guidance, although it just mirrors the exact wording of the legislation.

Yes Campden might be able to provide more details.

 

I can't believe the BFFF don't have a view on it though, the question will be if they share it externally if you're not a member.  Possibly worth a try? 

 

There are some IQF specifications on the Campden website but not for chicken:

 

Quick frozen food specifications at Campden BRI

 

And it looks like it's an area they're not specifically working on now but having said that they should be able to advise on legislation interpretation.