8 replies to this topic

[Technicallytim]

I work for a company who have recently started selling cream based sauces (i.e. cheese sauces, soups etc). We have adopted a model of thoroughly pasteurising in the pouch. We have proven these microbiologically with a lab for 3 month+ chilled shelf life (and some testing at ambient) and never come back with a bad result (also organoleptically tested fine). 

We have a huge freezer store but only a small chilled storage area. Before we started pasteurising (and until now) we have always stored and sold frozen.

My boss would like to label the product before freezing with a 12 month frozen shelf life with a statement along the lines of "once defrosted use within 3 months". I am trying to explain why this is not a suitable suggestion with the risk that someone defrosts it and that's such a period of time that they may forget when it was defrosted and keep it beyond that date. My boss is under the impression that this would be the customers fault for not ours but I don't think it gives clear advice, its the whole reason we apply a use by date and don't just label a tin "use within 1 year". Plus I have never seen this on anyone else's label. 

How can I persuade him that we will have to apply a use by date upon defrost, is there any legislation / guidance I can show him that will help?

[jfrey123]

American here, but I think your boss' idea is fine.  I routinely see items with long shelf lives that have separate instructions once opened or used.  As an example, I just grabbed a carton of chicken stock out of my refrigerator.  It is sold and stored ambient, and it states on the top, "Best if Used By 21 May 2026."  Then on the side, it states, "Keep at ambient storage for 12 months.  Keep refrigerated for 7 days once opened." 

 

Another carton of my wife's oatmilk is sold ambient, and states "Refrigerate after opening.  Use within 7-10 days."

 

Some frozen salmon steaks in my freezer state "Best if Used By Feb 4 2026", then has printed "Keep Frozen.  Then Thaw Under Refrigeration."

 

So I think there's some potential for a statement like "Keep Frozen Up to 12 months.  Use within 3 months if thawed.  Use within 7-10 days from opening." (or however long you recommend from when they open it).  I would just advocate the information all be in one place so no regulator can claim you are unclear with the instructions.

[GMO]

Does your pasteurisation reach temperatures high enough to kill Clostridium botulinum?  Or are there other hurdle factors (e.g. pH)?  That's what I'd have a look at.

 

The chilled food association in the UK has some great resources on this and if you're looking for chilled shelf lives over 10 days, I'd recommend doing their SUSSLE course.

 

SUSSLE & the 10 Day Rule for Shelf Life - Chilled Food Association

 

If you're above 90/10 or equivalent it might be an easy one.

[kconf]

I agree with Jfrey. I have seen lots of day to day products labeled how your boss wants. 

[GMO]

I have to admit I've not seen a UK label with a post defrosted shelf life as long as 3 months and that was the reason for my previous comment, that most chilled shelf lives are restricted to 10 days unless heat treated with a C Bot cook, ideally in pack or hot filled or with a different set of micro hurdles. That would be no different if it had a long chilled life post freeze vs a short one.

 

But you do find "defrost and use within xx time" pretty routinely.  It just tends to be pretty short.

 

For example, a cake from a freezer, use within 24 hours Morrisons Triple Chocolate Gateau - Morrisons Online Groceries & Offers

 

I don't think "defrost and use within..." is a problem per se, just have you captured the C Bot risk (as pasteurisation wouldn't be enough, even in pouch) and if you have, why would a customer need chilled life that is that long?  I'd personally err to the side of caution as if this is for catering use, it's unlikely a kitchen would need to defrost several months worth nor want that hanging around their fridge for so long.

 

If you do go for it, I'd be tempted to put something on the pack to make it easy for the kitchen to write "defrosted on..." so they can track it.  They should of course have their own labels but it might nudge the right behaviour.

[Technicallytim]

The product goes through a 90C for 10 min C bot cook and then is pouched while hot. It then has a 30 min pasteurisation in boiling water, ensuring that the product is >90C for >10mins again. 

 

The products are designed for home cooks and are delivered to the customers home address (where it often arrives defrosted). We have had lab tests for various bacteria including C bot after >3 months and have always had clear results. 

 

I just think the defrost and use withing ... months isn't practical advise. If i pulled something out the freezer 3 months ago i am going to struggle to remember exactly when it was defrosted. 

I think the best solution is to defrost the product in our care and re-label it after its defrosted to state chilled storage information and a 3 month shelf life. 

 

"But you do find "defrost and use within xx time" pretty routinely.  It just tends to be pretty short." - My thoughts exactly, we also sell some raw frozen fresh product and I don't have a problem labelling these "once defrosted use within 3 days" but I think 3 months carries a risk of use not giving clear, practical advice.

 

I have to admit I've not seen a UK label with a post defrosted shelf life as long as 3 months and that was the reason for my previous comment, that most chilled shelf lives are restricted to 10 days unless heat treated with a C Bot cook, ideally in pack or hot filled or with a different set of micro hurdles. That would be no different if it had a long chilled life post freeze vs a short one.

 

But you do find "defrost and use within xx time" pretty routinely.  It just tends to be pretty short.

 

For example, a cake from a freezer, use within 24 hours Morrisons Triple Chocolate Gateau - Morrisons Online Groceries & Offers

 

I don't think "defrost and use within..." is a problem per se, just have you captured the C Bot risk (as pasteurisation wouldn't be enough, even in pouch) and if you have, why would a customer need chilled life that is that long?  I'd personally err to the side of caution as if this is for catering use, it's unlikely a kitchen would need to defrost several months worth nor want that hanging around their fridge for so long.

 

If you do go for it, I'd be tempted to put something on the pack to make it easy for the kitchen to write "defrosted on..." so they can track it.  They should of course have their own labels but it might nudge the right behaviour.

[GMO]

Ah!  I understand this better now.

 

So if it's for consumers, this is definitely more dubious. But also the fact it's likely to have defrosted en route. 

 

Your boss can't abdicate responsibility here.  Reasonably expected consumer misuse is something you should think about with HACCP and things like this didn't stop the Listeria in frozen veg recall for example, even though it says on pack and always has done that you should cook it.

 

Would it be an option to label as you pack for the customer with the new life?  Because that's when it should really start, not at the consumer's house. Whatever life you then choose of course.

[Technicallytim]

Ah!  I understand this better now.

 

So if it's for consumers, this is definitely more dubious. But also the fact it's likely to have defrosted en route. 

 

Your boss can't abdicate responsibility here.  Reasonably expected consumer misuse is something you should think about with HACCP and things like this didn't stop the Listeria in frozen veg recall for example, even though it says on pack and always has done that you should cook it.

 

Would it be an option to label as you pack for the customer with the new life?  Because that's when it should really start, not at the consumer's house. Whatever life you then choose of course.

This is what I have been pushing for. To put the label on when we bring it out the freezer with chilled storage instructions and apply a shelf life at that point. However, operationally this is an extra step as its much easier to label the bags before packing. So I was hoping for some definitive legislation that i can show them to help prove my case.

[GMO]

That's where you might be in luck as you aren't providing it frozen, if it's defrosting en route, you are supplying it chilled.  

 

The legislation is pretty clear, it should have a BBD or Use by and as you're supplying it chilled, that should relate to the chilled life.

 

Food Information Regulations 2014

 

Now how you do that might be open to interpretation and you could potentially automate it but I can't see how you can circumvent it or say the frozen life is ok when that frozen life stops when you take it out of the freezer, not the consumer.