Is it getting chilly in here? Cooling as a CCP in Meat

I talk a lot on this blog about broad food safety issues, but today, I am going to talk about a specific CCP point as it occurs in both Fully Cooked RTE foods, and Heat Treated, Not Fully Cooked, not RTE foods.

When writing a meat/poultry HACCP the CCPs we put in control for Physical, Chemical, or Microbial hazards.  Most of the time, we spend a lot of time worrying about what those microbes are doing on our meats.  Writing a heat treatment CCP makes us feel all good because we are killing a lot of those microbes.

But we don't kill the spore formers.  Those Clostridia and Bacillus can survive boiling water, freezing cold, and pretty much all the chemicals we might want to throw at them.  The spore itself is pretty fascinating.  However, what spore forming bacteria can do to us and our food can be problematic at one end of the spectrum, and deadly at the other end of the spectrum.

When spore forming bacteria are heated, they form their spore, lie dormant till the threat is passed, then return to their normal, active vegetative state where they are the greatest threat to health, because they are making toxins and multiplying.  Cooling food can spend a lot of time in the danger zone of these bacteria.  Ergo, we must cool them quickly so that the spore formers go dormant once again.  

Clostridia is especially active at 130F to 80F and thus cooling must be as rapid as possible within that range.  But keep in mind, that cooling (like heating) is a dynamic process that takes place at a different rate in different cuts of meat.  A uniformly ground and packed sausage will heat and cool uniformly.  A bone-in ham will not.  And a bone-in ham will cool at a different rate than a brisket.  The cooling of the product depends on the temperature differential between the hottest portion of the piece and the coldest portion of the piece (for you calculus types this is dT/T).  The greater the difference between the hottest part and the coldest the more rapid the cooling.  So what can a processor do to speed things up?

Use potable water to continually chill the outside of the meat.

Put the meat through a tunneling system.

Put the meat in the freezer

FSIS really likes it if the meat can drop from 130F to 80F in 1.5h and then to 40F in 5h (Option 1).  

Keep in mind though that cooling meat puts heat in the air, hot air rises, hits the cool ceiling of your establishment, cools and condenses.  And that my friends brings out the Listeria!  But that is a post for another day.

Many small processors don't have the myriad of expensive equipment to cool the meat and handle the moisture in a way that satisfies Option 1 of Appendix B which leaves cooling meats in the finished product cooler under Option 2, which brings the temp from 120F to 55F in no more than six hours.

Both options are valid.

But, you have to test that the cooling is occurring in all parts of the meat, in all the sizes you are using.  Thermometers and time temperature graphs are a great way to test this.  

Interested in learning how to make a validation test?  Send me an email for a validation testing procedure.

Labeling out of RTE

Back in September, the USDA rolled out a new Listeria Compliance Guideline.  At first glance this Guideline seems to be only for RTE foods.  Fair enough, that's where Listeria is most problematic.

But, Attachment 1.2 updates how they consider products that receive a full lethality treatment that are not RTE, and are not defined as such by 9CFR 430.1.  Value added products that are not hot dogs or deli meat can now be "labeled out" of RTE status.  Producing those products under a Heat Treated, Not Fully Cooked, Not Ready To Eat, then labeling them as NRTE, and clearly marking them with cooking instructions, now seems to be an acceptable way to put cooked product into the marketplace, without having to comply with Listeria controls.

This means that plants that have hesitated to put smoked meats, pot pies, or frozen dinners into the marketplace, now have clear and concise guidelines on what to do and how to justify their decisions.  Thanks USDA!

Do you have a product that you are wondering about?  I offer free initial phone consultations on HACCP and other food safety plans.

Listeria control

Listeria.  It's in the drains, it's in the soil, it's on the shoes of the workers that walk into your building.  And if you are making a Ready To Eat (RTE) product, it can be a really big problem.  USDA guidelines  gave some great advice to processors on how to approach their listeria control program.  In short, if you are producing a product that is readily identifiable as RTE and they have risk for environmental exposure you must implement one of three regimens to control Listeria.

Alternative I- Post lethality treatment (PLT) and antimicrobial agents or processes (AMA and AMP respectively).  This option works for conventional products that can be preserved and cooked in their packaging

Alternative II- PLT or AMA/AMP

Alternative III- Implementation of a sanitation program to control Listeria

So, does your product require listeria control?  Ask yourself these questions:

1. Is it Ready to Eat?  Or, if it is on the fence (like frozen dinner) are you planning on labeling yourself out of a RTE category?
2. Is it exposed to listeria after the final pathogen control step in your HACCP?

If the answer is yes to both of those questions, then you need to implement the Listeria Rule.