Cured Products Question/Scenario:
According to Appendix B (June 1999) "Compliance Guidelines for Cooling Heat-Treated Meat and Poultry Products (Stabilization)" cured products can be chilled more slowly than non-cured products.
Appendix B states:
"The following process may be used for the slow cooling of ready-to-eat meat and poultry cured with nitrite. Products cured with a minimum of 100 ppm ingoing sodium nitrite may be cooled so that the maximum internal temperature is reduced from 130 to 80°F in 5 hours and from 80 to 45°F in 10 hours (15 hours total cooling time)."
Some establishments have been informed that this statement only applies to pumped or brine cured products. Is that correct, or can it be applied to all cured products, including sausage?
Response:
Many cooked products that are produced do not fall under the performance standard regulations for lethality and stablilization. However, the agency has made the determination that if an establishment produces any cured product containing 100 ppm of nitrite, the slow cooling process can be used to produce safe products. This applies to all cured products.
This response was provided by Mr. Bobby Palesano of the USDA/FSIS Technical Service Center in Omaha, Nebraska.
Temperature Monitoring Question/Scenario:
Can an establishment design a CCP that has product temperature as a critical limit, but monitor the cooler temperature providing that they have data to show the relationship between cooler and product temperature? For example, an establishment determines that cold storage of raw materials is a CCP, and that the critical limit is 45°F product temperature. For this scenario, let's assume that the establishment has collected data -- multiple temperatures of product at various cooler temperatures -- to demonstrate the product and cooler relationship and the establishment knows what cooler temperatures will maintain the product temperature at or below 45°F. Therefore, they set their monitoring activity as daily monitoring of the cooler temperature rather than the product temperature. Providing the data are available, can an establishment design a CCP that has product temperature as a critical limit, but monitor the cooler temperature?
Response:
In most situations, establishments do not have correlation data available to have product temperature as the critical limit and monitor the room temperature. However, in the scenario described above, I see no reason that an establishment could not have product temperature as the critical limit and monitor the room temperature. The establishment would need to have data to correlate the room and product temperatures and might even want to take product temperatures at some frequency as part of a verification activity to ensure the HACCP system is functioning as intended.
This response was provided by Mr. Bobby Palesano of the USDA/FSIS Technical Service Center in Omaha, Nebraska.
Pre-Shipment Records Question/Scenario:
Many very small establishments may store a wide variety of finished products (raw and cooked) for several months in the freezer. If the HACCP plans that are being developed include a CCP for cold storage of finished products after processing, then must the CCP must be maintained and documented during the entire time the products are stored? Moreover, if a plant has a cold storage CCP for finished product, and is monitoring and documenting the critical limits on a daily basis, can they conduct a pre-shipment record review each morning that would "clear" the storage CCP for all of the products/inventory that is in the freezer at that time? If so, this would allow them to "ship" products that were in the freezer that morning throughout the day. Then the next morning they could monitor and document the CCP and "clear" pre-shipment for everything in the freezer. Do you think this type of scenerio would meet the pre-shipment review requirements for this CCP?
Response:
There is nothing that would prohibit the establishment to do pre-shipment in the morning to "clear" product that has been produced up to that point. Regulations 417.5(c) do not prescribe how establishments meet the pre-shipment requirement and the agency is sufficiently flexible to accommodate various records' review schemes. In this scenario, the important thing that establishments should consider is the monitoring frequency. The monitoring frequency should be adequate to demonstrate process control to meet the regulatory requirements of 417.5(c).
This response was provided by Mr. Bobby Palesano of the USDA/FSIS Technical Service Center in Omaha, Nebraska.