Mike and Enrique,
It really comes down to how short of a recording time interval will
satisfy the "continuous" monitoring expectation of FDA. The agency
generally accepts datalogging instrumentation which record at preset
intervals (hopefully, appropriate for the process) and are not truly
continuous. These devices would appear to remove the human element but
a distinction should be made between continuous monitoring and
continuous record-keeping. Even a cook recorded by an ink-on-paper
continuous chart must be periodically monitored by the operator. If, by
nature of the process, the smokehouse operator must check every five
minutes to determine the end of cook (product endpoint temperature),
then an argument can be made that any record verifying this activity, or
even just the final endpoint temperature, should satisfy the
record-keeping requirement of the HACCP regulation. The record must
document that critical limits are met, or if not, that appropriate
corrective actions are taken. Nothing in the regulation mandates the
use of continuous record-keeping devices to satisfy this requirement.
Someone from FDA, care to weigh in?
Tom
Thomas E. Rippen
Seafood Technology Specialist
Sea Grant Extension Program
Center for Food Science and Technology
University of Maryland Eastern Shore
Princess Anne, MD 21853
410-651-6636
410-651-8498 fax
terippen@umes.edu
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
Behalf Of Enrique Reinoso Pin
Sent: Wednesday, November 01, 2006 2:42 PM
To: Strang, Mike; HACCP mailing list (HACCP mailing list)
Subject: Re: continuous monitoring
Mike
If you monitoring every time it is continuos. If you monitouring every 5
minutes it is imtermitent.
Enrique Reinoso
enriquereinoso@hotmail.com
----- Original Message -----
From: Strang, Mike <mailto:Mike.Strang@us.fjordseafood.com>
To: HACCP mailing list (HACCP mailing list)
<mailto:seafood@ucdavis.edu>
Sent: Wednesday, November 01, 2006 2:11 PM
Subject: continuous monitoring
Another question concerning continuous temperature monitoring.
We are monitoring internal fillet temperatures during a cook. We
probe 3 of the thickest fillets with thermocouple probes, we read and
record the fillet temperature every 5 minutes during the cook once all
of the 3 fillets have reached the critical temperature.
Why would this not be considered continuous monitoring?
Mike Strang, QC Manager
Ducktrap River of Maine
57 Little River Drive
Belfast, Maine 04915
mike.strang@us.fjordseafood.com
Ph: 800-508-7968
Fax: 207-338-6288
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