Anne,
If you can prove that by controlling belt speed and steam tunnel temperature
that each and every product exiting the cooker will have reached the
appropriate internal temperature, then you could, IMHO, use belt speed and
tunnel temperature as your critical limits for the cook step CCP.
Now, the question is, how can you prove it? You need to conduct a study
demonstrating how belt speed and tunnel temp are correlated with end product
temperature for each size product you are processing. Once this correlation
is known you can set belt speeds and tunnel temps. that are appropriate for
the product. Remember that each size product will require different
time/temp combinations. Initial product temp also would be a variable. You
can verify/validate the adequacy of the CCP by periodic monitoring of end
product temperature. Obviously continuous monitoring is best, but under
your circumstance you can continually monitor belt speed and tunnel temp.
Be sure to keep excellent records of the study and of subsequent monitoring.
Something that may help you with your inspector is to have an independent
process authority validate your operation.
FWIW,
Doug
********************************************
Douglas L. Marshall, Ph.D.
Professor, Mississippi State University
http://www.msstate.edu/dept/fst
Contributing Editor, Food Microbiology
http://www.elsevier.com
Department of Food Science & Technology
Room 110 Herzer, Stone Blvd (courier)
Box 9805 (mail)
Mississippi State, MS 39762-9805 USA
Ph 1-662-325-8722
Fax 1-662-325-8728
********************************************
“One of the sure signs someone is taking a mental vacation is when they want
to speculate about what the future will bring. We can act responsibly and
prudently in the present, on an intimate and community present. We can’t act
responsibly and prudently in the abstract future.” Scott Burns, April 11,
2002
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On
Behalf Of Anne
Sent: Tuesday, February 18, 2003 4:10 PM
To: seafood@ucdavis.edu
Subject:
Listservers,Thanks for the input last week.I realized
that I didn't word one of my questions well so maybe
I can reword it to make sense. I am very aware that
one CCP for shrimp would be the cook step, we had
used the belt speed and the time as our verification.We
were given the Okay to use the Crab process study that
the NFPA had done and use the core temp. as an
alternative to the time and temp. criteria. which we have done since 1999.
An FDA inspector has now told us
that this is not "Continuous" which is the word used in the guide.I don't
disagree but the guide suggests a temp. recording device and I am not all
that familiar with something that can be attached to the peelers.
I have a chart recorder to monitor our cooler,I understand the whats and
hows of its use pertaining to our cooler
temperature,but we need to put them on the shrimp peelers? I don't
understand that concept because the only
temp. it would be recording is the steam temperature, and
not a core temperature as we do now ,can someone
tell me what other processors use for the shrimp cook step verification
that would make the regulatory agencies
happy .This has been haunting me for months ..I'll be
grateful... Thanks again.
Anne Espedal
Bornstein Seafoods
Astoria,Or
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