We recently received a new USDA inspector who is very diligent about process and HACCP risk analysis. This morning, he told us that we are not in compliance due to chilling cooked chicken in an ice bath due to the increased volume of water that the chicken will absorb during the chilling process (the cooked chicken is a WIP for later addition as an ingredient in a meal kit.
We stated that we take weights before cooking and that weights are taken per ingredient per meal during the final assembly of the meal. He has stated that we are likely out of compliance with our ingredient order for water on our finished product label.
We have historical data that shows volume loss during the cooking process (yield is approximately 75% of raw weight after cooking). He disagrees with us and is telling us we need to include this risk in our HACCP process (which ingredient volume wouldn't be a food safety risk in the first place) and that we are going to get a non-conformance for HACCP risk analysis AND a potential NC for food fraud.
Does anyone have any advice or experience working with cooked chicken and water absorption or could point in me in the direction of resources to make our process more robust?
Any by all means, if I need to clarify anything to help with this opportunity please let me know.
Thanks!