Hi Liz,
It is our understanding, through the works of the Pacific HACCP Advisory Panel, that FDA and states of the Pacific region, are now allowing EPIPT (end-point internal product temperature) as an appropriate CCP for the crab cook step, in lieu of continuous time/temp CCP, provided the processor has "substantiating data" regarding the adequacy of the cooking system (i.e., has evaluated/verified adequate temp distribution), and has verified (through HP trials) that the "slowest heating product under the worst case heating scenario" reaches the proper EPIPT to acheive a 6D process for Lm. Done correctly, such cook system verification studies can most definitely account for potential "unit variability", and I think the regulators are now starting to accepting this fact. Again, the key is for the processor to have conducted some verification studies, to provided the regulators with the assurance that EPIPT is adequate for their system/product. Without substantiating data, however, they have indicated they will go
with the Hazard guide recommendations.
We has advised many of our seafood members in this regard, just in the past 6 months or so; with many members having conducted the verification studies mentioned above. As a result, they have sucessfully implementing EPIPT for control of their crab cook step, with no objection from the regulators. I have seen HACCP plans with appropriate supporting data for EPIPT done for king, snow, and dungeness sections so far, in both water or steam heating mediums; and for batch or continuous cook systems.
Your collegue up there, Don Kramer, was at the last Pacific HACCP Advisory panel meeting (Feb. '04), and may have additional materials for your use in this regard.
Best Regards,
Joe Frazier
NFPA Center for Northwest Seafood
1600 S. Jackson St., Seattle, WA 98144
Phone: (206) 323-3540, Fax: (206) 323-3543,
E-mail: jfrazier@nfpa-food.org
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-----Original Message-----
From: Liz Brown [mailto:bfeab@uaf.edu]
Sent: Thursday, June 10, 2004 11:45 AM
To: seafood
Subject: Re: Cooked Crab HACCP
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
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