Seafood HACCP for Vending Company Question

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

Hi biddlecom,

i don't quite understand the process, eg what you mean by "driver", "run".

Is this a human driver or a robot component going backwads and forwards ?

Is the seafood haccp book you refer specific for secondary processors ?. If so does it define steps of such an action as a CCP ? (i am only familiar with Fishery haccp guide for Processors which from memory has a similar table to that you mention).

I anticipate that practically you are going to have to do some validation  "worst case" test runs, eg obtain a temperature profile of a marked sandwich sample located at the warmest point during the action you describe - temp. typically measured by a thermocouple at the warmest internal sandwich location.

PS - i suspect the "not" following "seafood haccp book" is a typo ?

addendum -

i deduce your references are to the attachment in this related post/thread -

http://www.ifsqn.com...od/#entry103029

the potential FDA, CCPs maybe as per -

san1 - sandwiches CCPs.png   107.53KB   0 downloads

Yr quote in OP seems incomplete -
 

 

Alternatively, if the product is never
held at internal temperatures above
80°F (26.7°C), exposure times at internal
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
(21.1°C);

 

Pg 235, Fishery Guidance 2011

driver is human, run means the drivers route that he "runs" to deliver product.

I have worked with food service companies, similar situation, involved explanation - however it all boils down to this, you need highly accurate probe thermometers and I would not leave temp taking up to the drivers, this needs to be handled by QA.  And I question the use of cooler bags, that is what they use to deliver the sandwiches in bulk?  Who is checking the temps of the cooler bags, how often are they opened, are these checked for temp, who checks the vends for temps, etc.

It really becomes a really big deal very quickly.

So what happens is. The driver (person who goes from vending machine to vending machine – Delivery Man) takes a tray of RTE sandwiches out of the fridge and grabs the ones that he needs for his delivery route and puts them in a box.  He then puts that tray back in the fridge.  He will then grab the box and put it in an insulated cooler bag then put a frozen cooler plate on the top of the box and close the bag.  This bag is then placed on a non-refrigerated truck.  The bag could be opened multiple times during the delivery route.

So I figured this would be my route.  I would validate the sandwich “picking” process by using a NIST thermometer.  I would probe one of the sandwiches on the tray and leave that in during the whole driver picking process.  I would then verify that the internal temperature of the sandwiches never went over the mark for more than 4 hours.  I would then audit that validation periodically.

As for the delivery I would do validations on product in the bags by doing the same thing with the NIST thermometer.  I could do a bag closed for 8 hours and then a bag that gets opened multiple times a day for 8 hours.  I can then audit that process with our continues temperature units that we can stick in the bag during the route. 

As for the machines they will have a continues temperature unit in them that links to the internet so you can check it anytime.

By mark I assume you mean 10degC

I assume the start temp. is ca. 4degC

I deduce the only cooling during run is applied external to cooler bag.

You need to determine the worst case option for any related variables to make any validation attempt meaningful, eg with respect to product, packaging, route, driver, cooler bag, length of run, whatever.

The test should presumably also be "blind" but this may be not possible.

You will need multiple samples within a run, and multiple runs

I anticipate the variations in yr data will be substantial and averages rapidly go  > 10degC, maybe depending on the cooling temp produced by the cooler plate).

Offhand, if you have a budget, i believe you can get small  "chips" which can simply be inserted into a sandwich and store the T vs t  data for later download.

Good Luck !