HACCP for cryovac

Our health department (new guy in town) says that he is going to require us to submit a HAACP plan for cryovacing product for resale. We will be taking frozen product and repackaging into smaller packages and cryovacing for longevity and for "boil-in" convenience. All the time remaining a frozen product. We will also be doing the same thing with some refrigerated product where we bring it out repackage smaller and refrigerate.

What kills me is that if we repackage it in a lesser manner say on styrofoam with saran wrap over it, no problem at all. But to use the cryovac, and package it better, he wants a HACCP plan.

Does this sound odd? This guy seems to be fresh out of college and I think that he is just scared of the machine and doesn't really know what it is. That or I am missing something with what potential hazard lies in it's operation that I may not know about.

Great site. I've been going through everything for a couple hours now. Lots of good info in here.

Dear CSSF,

Interesting business and welcome to the forum. May I enquire what kind of product you are repackaging.

It could be that yr health guy has read the FDA self-assessment defect list for its inspectors and got nervous, I noticed this one -

" # A firm is producing fresh, raw, refrigerated fish in Cryovac™ packaging. The inspector is not aware that C. botulinum is a significant hazard. "

http://www.fda.gov/o...-AppendixB1.htm

Rgds / Charles.C

Little bit of everything. We deal in wild game that comes from farms and meets all the standards and is cryovacced already. We will be taking whole loins down to steaks etc. with a bandsaw. He never said anything about having a problem with the bandsaw. That will be the frozen type stuff that we will be doing. Refrigerated will consist of various meals such as spaghetti, pulled pork (we are the only people in the county with a smoker), etc. that will be cooled after completeion, and then cryo'ed.

Dear CCSF,

You have some interesting microbiological possibilities in yr worksheet !

I guess spahetti etc are ready- to- eat meals after consumer microwave or something similar. I am surprised this kind of production mix didn’t attract oficial requests for haccp flow charts etc from the beginning (my guess is would happen in UK). Maybe US is more trusting of private entrepreneurs or previous inspectors had been scared of the bandsaw .
Now I suppose you have to study the Food Code or do you come under the meat control function, seem to remember that FDA and USDA split the monitoring responsibilities in USA.

Rgds / Charles.C