Food Safety Plan and Filed Processes
Good Morning,
I am sorry if their is a post related to this, I just haven't found what I am looking for. I work in regulatory at a sauce production facility and we are in the middle of converting over to Food Safety Plans. We were able to lump many of our sauces into the same plans due to having the same CCP's, cooking steps, etc. One particular plan has 12 different products in it (these are heated). Three of these products have filed processes. When we write our hazard analysis we always write our products to the government minimum. Example: We state we only have to heat sauces to 163*F but in reality we go above and beyond this heating sauces to between 180-200*F. This way we are covered. In our process filings our minimum fill temp is higher than what is stated in our hazard analysis. So my question is do we have to reference these process filings in our Food Safety Plan? Since according to process filing 163*F cannot be the minimum heating temp but the 163*F covers us on the minimum heating temp by the FDA. Thanks for the help! This has been a debate in my workplace recently.
we always write our products to the government minimum
Well, you would if you were doing a normal cook, however you are producing this product under your process filing, which according to the government, you cannot produce this product under any conditions other than the process you filed, you created a new government minimum.
Generally, CCP should refer to the number you have to hit to avoid recall or disposal, since you submitted a process filing with a minimum temperature, you cannot sell that product if you don't adhere to the process filing, therefore that's the critical limit.
What you can and should do is set your critical limit in your food safety plan to the minimum number outlined in your process filing, and on your monitoring records add a small buffer as you indicated above (like 5º) so that you can avoid recalling in the event that the you have thermometer calibration issues or "close" ccp failures on the line from equipment or personnel malfunction.
If you want a broader temperature range for your food safety plan, submit a new process filing with the minimum temperature necessary to produce the product safely, then you can update your plan and records.