I work at a Vending company that is considered a secondary processor of seafood. We have ready to eat prepackaged tuna and seafood sandwiches. Our seafood products are stored in uprite coolers. The drivers will take the sandwich trays out of the cooler and load their cooler bags with the sandwiches they need for their run. Then they will put the sandwich tray back into the cooler and the next driver will do the same. This goes on for a couple of hours.
According to the Seafood HACCP book essentially if the fish is not held at temperatures above 50°F (10°C) should be limited to 4 hours, as long as no more than 2 of those hours are above 70°F (21°C).
So does that mean I am safe to say that within the couple hour period were the drivers are taking the tray out of the fridge and placing it back in that the food is safe and a CCP will be in place to confirm the food is safe?
My next question is, is how would I control and prove that? example - First driver temps the sandwiches and then last driver temps the sandwiches to prove they are not above 70°F (21°C) within the two hour period?
Any help would be great. Thanks