Dear Al,
Is there a good reason not to put Listeria m. in a raw meat HACCP, other than political issues???
Well, to get back to basics, this is a quote from a standard
HACCP text –
(
http://europe.ilsi.o...LSIHACCP3rd.pdf )
Another example deals with the selection of significant hazards from the list of potential hazards. This selection is based on the likelihood of their occurrence in the final product at levels that are unacceptable. Thus, judgements have to be made and decisions have to be taken based on quantitative considerations.
The “judgements” have to be made at each step of your process of course as per yr original attachment.
If you wish to be very quantitative, can set up a FSO.
From the same text -
"
Examples of technical data that may be required for a HACCP study1. Epidemiological and legal data on microbial pathogens, toxins and chemicals
a Incidence of foodborne illness (especially if related to similar product)
b Results of surveillance programmes and sentinel studies
c Legal microbiological food safety criteria and Maximum Residue Limits
2. Food Safety data
a Likely presence of microbiological and chemical hazards in raw materials (see category 1 above)
bGrowth rates of pathogens in food products
c Death rates of pathogens under a range of conditions
d Fate of chemicals and toxins during processing, storage, distribution and use
3. Raw material, intermediate and final product data
a Formulation
b Acidity (pH)
c Water activity (aw)
d Packaging materials
e Product structure
f Processing conditions
g Storage and distribution conditions
h Shelf life
i Consumer use instructions, package labelling, including code dating practices
4. Processing data
a Number and sequence of all processing stages including storage
b Range of product time/temperature conditions
c Handling of rework (recycled material from the manufacturing process)
d High/low risk area separation
e Flow conditions (for liquids)
f Presence of void spaces in processing equipment
g Efficacy of cleaning and disinfecting
Some thoughts -
The immediate relevant items are perhaps 1(a,b), 2(a,b), 3 (i), 4(a,b,g)
1a is obviously highly important from a health viewpoint. Presumably this data exists for yr situation.
(there is also a ranking list of bacterial species "severity" in another forum thread although I think the tendency is to group the common pathogens as "severe" in terms of potency).
1b will, sadly, be important even if you don’t agree with the legal numbers (and they may not be validated). Whether or not this item is justified as being directly linked to
HACCP is debatable IMO but it is a fact of life.
2a,b this thread has just been discussing. Do you think that for yr process, the temperature/times, eg chilling, involved will permit (significant) growth of any L.monocytogenes (and any other pathogens ??). If not, perhaps you shud not consider chilling to be a
CCP. But do the local regulations (auditors??) demand it anyway ?? (regulatory
CCP?)
3i – do You trust the consumer to properly cook?. Some generic
HACCP plans do and classify salmonella in the raw material as a non - significant pathogen. This seemingly ignores the possible ampont of pathogen and any xcontamination effect to the factory environment. And then you maybe hv to consider 1b again.
4a.b. Depends on Yr process.
4g. How much L.mono in Yr environment?
Rgds / Charles.C