| U.S.
Food & Drug Administration Center for Food Safety & Applied Nutrition FISH AND FISHERIES PRODUCTS HAZARDS AND CONTROLS GUIDANCE: Third Edition June 2001 |
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The introduction of pathogens after pasteurization and certain cooking processes can cause consumer illness.
Pasteurization is a mild or moderate heat treatment, usually performed on fishery products after the product is placed in the hermetically sealed finished product container. The purpose of pasteurization is to either: 1) make the product safe for an extended refrigerated shelf-life, which, in most cases, involves eliminating the spores of Clostridium botulinum type E and nonproteolytic B and F (the types of C. botulinum most commonly found in fish); or 2) eliminate or reduce the numbers of other target pathogens (e.g. Listeria monocytogenes, Vibrio vulnificus, Vibrio parahaemolyticus).
In addition to eliminating pathogens, the pasteurization process also greatly reduces the number of spoilage bacteria present in the fishery product. These bacteria normally restrict the growth of pathogens through competition. Rapid growth of pathogens that may be introduced after pasteurization is, therefore, a concern. This chapter covers control of recontamination after pasteurization.
For some products that are marketed refrigerated, cooking is performed immediately before reduced oxygen packaging (e.g. vacuum packaging, modified atmosphere packaging). For these products, the cooking process is targeted to eliminate the spores of Clostridium botulinum type E and nonproteolytic types B and F, particularly when the product does not contain other barriers that are sufficient to prevent growth and toxin formation by this pathogen (e.g. many refrigerated, vacuum packaged hot-filled soups and sauces). These cooking processes, which are discussed in Chapter 16, have much in common with pasteurization processes, which are discussed in Chapter 17. For example, control of recontamination after they are placed in the finished product container is critical to the safety of these products. Additionally, because these products are cooked before they are packaged, they are at risk for recontamination between cooking and packaging. The risk of this recontamination is minimized by filling the container in a continuous filling operation while the product is still hot (i.e. hot filling), another critical step for the safety of these products. This control strategy is suitable for products that are filled directly from the cooking kettle, where the risk of recontamination is minimized. It is not ordinarily suitable for products such as crabmeat, lobster meat, or crayfish meat, or other products that are handled between cooking and filling. Hot filling is covered in this chapter.
There are three primary causes of recontamination after pasteurization and after cooking that is performed immediately before reduced oxygen packaging. They are:
Poorly formed or defective container closures can increase the risk of pathogens entering the container, especially during container cooling performed in a water bath. Contaminated cooling water can enter through the container closure, especially when the closure is defective. Container closure can be controlled by adherence to seal guidelines that are provided by the container or sealing machine manufacturer. Control is accomplished through periodic seal inspection.
Contamination of cooling water can be controlled by ensuring that a measurable residual of chlorine, or other approved water treatment chemical, is present in the cooling water, or by ensuring that ultraviolet (UV) treatment systems are operating properly.
Recontamination between cooking and reduced oxygen packaging in continuous filling systems where the product is packaged directly from the kettle can be controlled by hot filling at temperatures at or above 185°F (85°C). FDA is interested in information on the value of adding a time component (e.g. 3 minutes) to this hot filling temperature recommendation, to provide limited lethality for any nonproteolytic C. botulinum spores present on the packaging material.
It may also be prudent to use packaging that has been manufactured or treated to inactivate spores of C. botulinum type E and nonproteolytic types B and F (e.g. gamma irradiation, hot extrusion). FDA is interested in comment on the utility of such measures.
There are a number of strategies for the control of pathogens in fish and fishery products. They include:
At each processing step determine whether "introduction of pathogens after pasteurization" is a significant hazard. The criteria are:
1. Is it reasonably likely that pathogens will be introduced at this processing step (consider post-pasteurization processing steps, only)?
It is reasonable to assume that, in the absence of controls, pathogens of various types may enter the finished product container during a water bath cooling process or between cooking and reduced oxygen packaging.
2. Can the introduction of pathogens after pasteurization be eliminated or reduced to an acceptable level here? (Note: If you are not certain of the answer to this question at this time, you may answer "No." However, you may need to change this answer when you assign critical control points in Step #12)
"Introduction of pathogens after pasteurization" should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate (or reduce the likelihood of occurrence to an acceptable level) the hazard, if it is reasonably likely to occur.
Step #10 discusses a number of pathogen control strategies. This section covers control of pathogen introduction that can occur after the pasteurization process and between cooking and reduced oxygen packaging. Preventive measures for the introduction of pathogens at these times can include:
List such preventive measures in Column 5 of the Hazard Analysis Worksheet at the appropriate processing step(s).
If the answer to either question 1 or 2 is "Yes" the potential hazard is significant at that step in the process and you should answer "Yes" in Column 3 of the Hazard Analysis Worksheet. If neither criterion is met you should answer "No." You should record the reason for your "Yes" or "No" answer in Column 4. You need not complete Steps #12 through 18 for this hazard for those processing steps where you have recorded a "No."
It is important to note that identifying this hazard as significant at a processing step does not mean that it must be controlled at that processing step. The next step will help you determine where in the process the critical control point is located.
In determining whether a hazard is significant you should also consider the intended use of the product, which you developed in Step #4. However, for those fishery products which are currently pasteurized, it is unlikely that the intended use will affect the significance of the hazard.
However, if your product is immediately frozen after processing, maintained frozen throughout distribution, and labeled to be held frozen and to be thawed under refrigeration immediately before use (e.g. "Important, keep frozen until used, thaw under refrigeration immediately before use"), then formation of C. botulinum toxin may not be a significant hazard.
For each processing step where "introduction of pathogens after pasteurization" is identified in Column 3 of the Hazard Analysis Worksheet as a significant hazard, determine whether it is necessary to exercise control at that step in order to control the hazard. Figure #A-2 (Appendix 3) is a CCP decision tree that can be used to aid you in your determination.
You should identify the container sealing step, the water bath container cooling step, and the hot filling step (where applicable) as the critical control points for this hazard. Therefore, you should answer "Yes" in Column 6 of the Hazard Analysis Worksheet for the container sealing, water bath container cooling, and hot filling steps. (Note: if you have not previously identified "pathogen introduction after pasteurization" as a significant hazard at the container sealing, water bath container cooling, and hot filling steps in Column 3 of the Hazard Analysis Worksheet, you should change the entries in Column 3 to "Yes").
This control approach is referred to as "Control Strategy Example 1" in Steps #14-18. It is important to note that you may select a control strategy that is different from that which is suggested above, provided that it assures an equivalent degree of safety of the product.
Proceed to Step #13 (Chapter 2) or to Step #10 of the next potential hazard.
At each processing step where "introduction of pathogens after pasteurization" is identified as a significant hazard on the HACCP Plan Form (e.g. container sealing, water bath container cooling and hot filling) identify the maximum or minimum value to which a feature of the process must be controlled in order to control the hazard.
You should set the CL at the point that if not met the safety of the product may be questionable. If you set a more restrictive CL you could, as a result, be required to take corrective action when no safety concern actually exists. On the other hand, if you set a CL that is too loose you could, as a result, allow unsafe product to reach the consumer.
As a practical matter it may be advisable to set an operating limit that is more restrictive than the CL. In this way you can adjust the process when the operating limit is triggered, but before a triggering of the CL would require you to take corrective action. You should set operating limits based on your experience with the variability of your operation and with the closeness of typical operating values to the CL.
Following is guidance on setting critical limits for the control strategy example identified in Step #12.
For container sealing:
Critical Limit: Container or sealing machine manufacturer's seal guidelines.
For container cooling:
Critical Limit: Measurable residual of chlorine, or other approved water treatment chemical, at the discharge point of the container cooling tank;
OR
Equipment manufacturer's UV light intensity and flow rate guidelines.
For hot filling:
Critical Limit: Product temperature of 185°F (85°C) or higher as the product enters the final container.
Enter the critical limit(s) in Column 3 of the HACCP Plan Form.
For each processing step where "introduction of pathogens after pasteurization" is identified as a significant hazard on the HACCP Plan Form (e.g. container sealing, container cooling tank and hot filling), describe monitoring procedures that will ensure that the critical limits are consistently met.
To fully describe your monitoring program you should answer four questions: 1) What will be monitored? 2) How will it be monitored? 3) How often will it be monitored (frequency)? 4) Who will perform the monitoring?
It is important for you to keep in mind that the feature of the process that you monitor and the method of monitoring should enable you to determine whether the CL is being met. That is, the monitoring process should directly measure the feature for which you have established a CL.
You should monitor often enough so that the normal variability in the values you are measuring will be detected. This is especially true if these values are typically close to the CL. Additionally, the greater the time span between measurements the more product you are putting at risk should a measurement show that a CL has been violated.
Following is guidance on establishing monitoring procedures for the control option discussed in Step #12. Note that the monitoring frequencies that are provided are intended to be considered as minimum recommendations, and may not be adequate in all cases.
For container sealing:
What: Container integrity
For container cooling:
What: Residual chlorine, or other approved water treatment chemical, in the cooling water;
OR
Intensity of UV light;
AND
Cooling water flow rate.
For hot filling:
What: Product temperature as the product enters the final container.
For container sealing:
How: Visual examination of containers (non-destructive):
OR
OR
AND
Detailed examination of containers (destructive):
OR
OR
For container cooling:
How: Measure residual of chlorine, or other approved water treatment chemical, at the discharge point of the container cooling tank;
OR
Use a UV light meter;
AND
Use a flow rate meter.
For hot filling:
How: Use a digital time/temperature data logger;
OR
Use a recorder thermometer.
For container sealing:
Frequency: Visual examination of containers: At least one container from each sealing head at least every 30 minutes of sealing machine operation. At a minimum this should include visual examinations made at the beginning of production, and immediately following a jam in the sealing machine, or machine adjustment, repair, or prolonged shut down;
AND
Detailed examination of containers: At least one container from each sealing head at least every four hours of sealing machine operation. At a minimum this should include examinations made at the beginning of production and immediately following a jam in the sealing machine, or machine adjustment, repair, or prolonged shut down.
For container cooling:
Frequency: For residual water treatment chemical: Sufficient frequency to assure control, but no less frequently than once every four hours of use;
OR
For UV light meter and flow rate meter: at least daily.
For hot filling:
Frequency: Continuous monitoring by the instrument itself, with visual check of the instrument at least once per batch of cooked product.
For container sealing:
Who: Monitoring may be performed by the sealing machine operator, a production supervisor, a member of the quality control staff, or any person who is trained and qualified to conduct container examinations.
For container cooling:
Who: Monitoring may be performed by the equipment operator, a production supervisor, a member of the quality control staff or any other person who has an understanding of the testing procedure and the critical limits.
For hot filling:
Who: With recorder thermometers and digital data loggers, monitoring is performed by the equipment itself. However, when such instruments are used a visual check should be performed at least once per batch of cooked product in order to ensure that the critical limits have consistently been met. These checks may be performed by a production employee, a production supervisor, a member of the quality control staff, or any other person who has an understanding of the process and the monitoring procedure.
Enter the "What," "How," "Frequency," and "Who" monitoring information in Columns 4, 5, 6, and 7, respectively, of the HACCP Plan Form.
At each processing step in which "introduction of pathogens after pasteurization" is identified as a significant hazard in the HACCP Plan Form (e.g. container sealing, water bath container cooling and hot filling), describe the procedures that you will use when your monitoring indicates that the CL has not been met.
These procedures should: 1) ensure that unsafe product does not reach the consumer; and, 2) correct the problem that caused the CL deviation. Remember that deviations from operating limits do not need to result in formal corrective actions.
Following is guidance on establishing corrective action procedures for the control option discussed in Step #12.
For container sealing:
Corrective Action: Identify and correct the source of the defect after a CL deviation;
AND
Evaluate the seriousness of the defects, and, if necessary, identify, segregate, and hold the affected product for appropriate follow-up action. That may include, but is not limited to, 100% visual inspection of all affected containers to remove the defective containers;
OR
Repack the affected product.
For container cooling:
Corrective Action: If no measurable residual chlorine, or other approved water treatment chemical, is detected, add chlorine or adjust the chlorine metering system and recheck for chlorine residual;
OR
If UV intensity is inadequate, replace or clean the bulbs or shields;
AND
If flow exceeds the critical limit, adjust or replace the pump.
For hot filling:
Corrective Action: Take one or more of the following actions to regain control over the operation after a CL deviation:
OR
AND
Take one of the following actions to the product involved in the critical limit deviation:
OR
OR
OR
OR
Enter the corrective action procedures in Column 8 of the HACCP Plan Form.
At each processing step in which "introduction of pathogens after pasteurization" is identified as a significant hazard and critical control point in the HACCP Plan Form (e.g. container sealing, water bath container cooling and hot filling), list the records that will be used to document the accomplishment of the monitoring procedures discussed in Step #15. The records should clearly demonstrate that the monitoring procedures have been followed, and should contain the actual values and observations obtained during monitoring.
Following is guidance on establishing a recordkeeping system for the control option discussed in Step #12.
For container sealing:
Records: Record of visual examination of containers;
AND
Record of detailed examination of containers.
For container cooling:
Records: Record of residual chlorine, or other approved water treatment chemical, levels;
OR
Record of UV intensity testing;
AND
Record of flow rate testing.
For hot filling:
Records: Printout from digital time/temperature data logger;
OR
Recorder thermometer chart.
Enter the names of the HACCP records in Column 9 of the HACCP Plan Form.
At each processing step in which "introduction of pathogens after pasteurization" is identified as a significant hazard in the HACCP Plan Form (container sealing, water bath container cooling and hot filling), establish verification procedures that will ensure that the HACCP plan is: 1) adequate to address the hazard of "introduction of pathogens after pasteurization"; and, 2) consistently being followed.
Following is guidance on establishing verification procedures for the control option discussed in Step #12.
For container sealing:
Verification: Obtain container seal guidelines from container or sealing machine manufacturer;
AND
Review monitoring and corrective action records within one week of preparation.
For container cooling:
Verification: Review monitoring and corrective action records within one week of preparation.
For hot filling:
Verification: Review monitoring and corrective action records within one week of preparation.
Enter the verification procedures in Column 10 of the HACCP Plan Form.
TABLE 18-1Control Strategy Example 1 - Control of recontamination This table is a an example of a portion of a HACCP plan relating to the control of the introduction of pathogens after pasteurization for a processor of pasteurized blue crab meat, packed in 301 X 408 size steel cans, using Control Strategy Example 1 - Control of recontamination. It is provided for illustrative purposes only. Pathogen recontamination after pasteurization may be only one of several significant hazards for this product. Refer to Tables 3-1, 3-2, and 3-3 (Chapter 3) for other potential hazards (e.g. chemical contaminants, pathogen growth and toxin formation during processing, pathogen survival through pasteurization, and metal fragments). Example Only | |||||||||
| (1) | (2) | (3) | (4) | (5) | (6) | (7) | (8) | (9) | (10) |
| Critical Control Point (CCP) | Significant Hazard(s) | Critical Limits for each Preventive Measure | Monitoring | Corrective Action(s) | Records | Verification | |||
|---|---|---|---|---|---|---|---|---|---|
| What | How | Frequency | Who | ||||||
| Container sealing | Pathogen introduction | No visible cutovers, seam sharpness, false seams, deadheading, droop, damage to the countersink wall indicating a broken chuck, cable cuts, product overlapping the flange, product leakage, or other obvious defects. | Container integrity | Visual seam examination | One can per seaming head every 1/2 hr, at startup, after jams, adjustments, repairs, and prolonged shutdowns | Seamer operator | Identify and correct the source of the
defect, and Evaluate the seriousness of the defect, and hold for evaluation if necessary |
Visual seam examination record | Review monitoring and corrective action
records within one week of preparation Can seam guidelines from can manufacturer |
| Cover hook: .070" minimum; body hook .072-.088"; width: .125" maximum; thickness .052-.058"; tightness 80%. | Container integrity | Double seam teardown examination, using micrometer at 3 points on seam, 120° apart. | One can per seaming head every 4 hrs, at startup, after jams, adjustments, repairs, and prolonged shutdowns | Seamer operator | Same | Double seam teardown record | Same | ||
| Water bath container cooling | Pathogen introduction | Measurable residual chlorine | Residual chlorine in water bath | Rapid test | Every batch | Pasteurizer operator | Add chlorine and recheck for residual | Processing record | Review monitoring and corrective action records within one week of preparation |
| Note: The critical limits in this example are for illustrative purposes only, and are not related to any recommended process. | |||||||||
See also:
Foodborne Pathogenic Microorganisms and Natural Toxins Handbook (Bad Bug Book)
Seafood Information and Resources
Seafood HACCP | Fish & Fisheries Products Hazards & Controls Guidance: 3rd Edition (2001)
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