>Ron,
>
>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 it is a very valid point and knowing the process specifics would be
critical. Given that even all ingredients are sterile whereby the process
itself is not can still make for a potentially hazardous product. What kind
of confidence in total sterility of the production environment can we have
in this case? I think that even under ideal sanitary conditions controlled
through prerequisites and RAP there still would be some chance for product
contamination during preparation with the risks for pathogenic bacteria to
grow to the level of concern over time. Therefore the length of exposure to
given temperatures for bacteria of concern should be critical. We may try to
play a bit with this part of the process while putting it through the
decision tree and asking some questions in the following sequence:
Loop A:
1. Does control/preventive measure exist?
And already knowing our hazard we may say 'no' (no time/temperature
control), that leads us to the next question:
2. Is control at this step necessary for safety?
Knowing our next step, which comprises simple freezing that does not
automatically eliminate the bacteria we may say 'yes', which requires us to
modify the step, process or product.
Or,
Loop B:
1. Does control/preventive measure exist?
And we may find that the answer is 'yes' since we buy and use only proven
ingredients and we also adhere to our SSOP/personal hygiene at this stage of
processing. This directs us to the next question:
2. Is the step specifically designed to eliminate or reduce the likelihood
of occurance of a hazard to an acceptable level?
Well, if we say 'yes', we have a CCP but more probably we would say 'no',
that leads us to:
3. Could contamination with identified hazards occur in excess of acceptable
level, or could this increase to unacceptable levels?
Since we adhere to certain purchasing practices, our SSOP as well as
personal hygiene we may say 'no' to the first sub-part of the question,
however 'yes' to the second one if we do not have time/temperature control
measures over our process and there are significant risks that the pathogens
would multiply beyond the safe level over time. Consequently:
4. Will a subsequent step eliminate the identified hazard or reduce
likelihood of occurance to an acceptable level?
And since the answer is 'no', therefore we definitely have a CCP and need to
determine critical limits.
Apologies for cutting and pasting.
Andrew Strak
>
>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>
>
> ****************************
>