your list of ingredients contains some cooked products but they are not
sterile and will support bacteria growth. You also plan to heat them for
mixing. So you definitely have the potential for growth of harmful bacteria
that came into your plant with the raw material even though when received
there may not have been hazardous levels. Then as someone else has already
pointed out, you have the potential for contaminating the product while it
is "in process". So you have the potential for a microbial hazard.
You need to take the next step in the hazard analysis and decide if it
(growth of pathogens) is "reasonably likely to occur" based on the
specifics of your process. If the product is heated during mixing to a
point where food poisoning organisms grow rapidly, then you probably should
have "time in process" as a CCP and set a CL to some reasonable value (like
maybe less than 2 hrs from mixing to freezing). The same logic would apply
for histamine formation if you used tuna that was not canned (commercially
sterile).
I think you make a mistake at the start by assuming that "previously
thermally treated product......processing under a HACCP
plan....[therefor].....pathogens will have been
destroyed before the product reaches the second processor". This might be
true for canned (commercially sterile) ingredients but not the refrigerated
cooked crab etc. you are going to mix into your hypothetical product. The
first processor may have reduced the number of pathogens to a safe level
(for the intended use and intended consumer), but you may be creating
conditions where a few remaining pathogens could increase to unsafe levels.
By the way, you do not mention the intended market for your product?
Identifying the consumer is one of the first steps in hazard analysis. You
don't plan to sell your product to NASA for the space shuttle do you? Or to
the hospital for the cancer ward?
Ken Hilderbrand
********************
At 09:16 PM 2/13/99 -0500, Ron Hoelzer wrote:
>I have a scenario for discussion since I have encountered several points
>of view:
>
> A seafood processor is going to make a seafood dish from products that
>have already been processed. He will be combining previously thermally
>treated product. These products will all be purchased from sources which
>are processing under a HACCP plan, hence, any pathogens will have been
>destroyed before the product reaches the second processor.
>
> The product will consist of the following:
>
> Cooked, refrigerated seafood (could be lobster, crabmeat, shrimp)
> Pasteurized dairy products,
> Spices and flavorings
>
> These ingredients will be heated to blend the flavors, but not heated
>enough to achieve any degree of kill activity.
>
> After heating the product will be dispensed into retail size containers
>and frozen.
>
> The question is - would there be any critical control points with this
>product?
>
>Ron Hoelzer
>Maine Food Technology Associates
>
>
------------------------------------------------------
Kenneth S. Hilderbrand Jr.
Seafood Processing Specialist
Oregon State University
Marine Science Center
2030 Sth Marine Science Drive
Newport Oregon 97365-5296
telno 541 867-0242 (and voice mail)
faxno 541 867-0138
email <ken.hilderbrand@hmsc.orst.edu>
****************************