Perhaps the FDA could respond to this.
A crab processor's HACCP plan was deemed inadequate because the critical
limit in their Listeria control CCP was an internal temperature of 195°F
which they ascertain by inserting calibrated thermometers in the
shoulders at two places in the cook basket at the end of each batch.
The inspector claimed that (1) the variability of temperatures in
different parts of the cooker made it essential to have both time and
water temperature included in the CCP for control of Listeria and that
(2) records could be too easily falsified.
My understanding is that the requirement for control of Listeria
monocytogenes is simply reaching an internal temperature of 185° for
0.02 minutes (that's from the Hazards Guide but other process experts
have listed 165° for a minimum internal temperature) so it seems that
any processor who reaches 195° is far exceeding safe levels. It is clear
that bluing would occur in any crab that has not been cooked well past
the listeria control point so there is a built in control mechanism as
customers will not buy blued crab.
This might be a case of the Hazards Guide being used as a regulation
rather than a guide. Just because Chapter 16 (Pathogen Survival Through
Cooking) gives an example of the water and temperature being used
doesn't mean that is the only way to achieve the critical limit
monitoring. I think there might be a very real danger inflicted if the
Alaska processing fleet is required to do a visual inspection of cookers
to see if the temperature is back up to boiling - the Bering Sea in
January is no place to be lifiting the lid of thousands of gallons of
210° water.
In the "Common Mistakes in HACCP - Cooked Crab" flyer I wrote: "#4 Not
calibrating equipment -You may choose one critical limit of an internal
temperature or two critical limits of cooking water temperature and time
cooked. Either way you must make sure you have achieved your cook
requirements." (http://www.uaf.edu/seagrant/Pubs_Videos/pubs/ASG-40.pdf)
and if I need to change the document to reflect current FDA practices I
will certainly do so.
Mostly I think the industry needs to know that all the inspectors are on
the same page on this or any other issue, especially issues that will
require either dangerous or expensive fixes.
Thanks in advance for responses.
-- Liz Brown Marine Advisory Program University of Alaska Fairbanks PO Box 1549 Dillingham, AK 99576 907-842-1265 Fax 907-842-3202
This archive was generated by hypermail 2b29 : Thu Jun 10 2004 - 11:51:15 PDT