Question Regarding Cooling for NRTE

Hi!

I work with a newly established company in Canada that makes frozen vegan meals in individual servings (like Michelina's line of product).

We are currently establishing our foods safety plan and have added CCP to cooking and was wondering if it is required to have a CCP for cooling if it is not ready to eat?

Our current operation involves cooking a batch of filling (sauce filling for chicken pot pies), cooling it in pails and then portioning it into pie tins with pie tops to be vacuum sealed and packed. One problem we are having is that our filling takes over 20 hours to hit 4°C from 80°C. We do not have the capacity in our walk-in freezer as we are in a commissary kitchen. 

We have sent micro samples out to prove that there is no risk of micro right now with our the filling is cooled and the product is labelled as NRTE (customers are provided cooking instructions).

May i take out cooling as a CCP and just put it in as a CP knowing that we dont have a risk?

Thank you!
 

Hi!

 

I work with a newly established company in Canada that makes frozen vegan meals in individual servings (like Michelina's line of product).

 

We are currently establishing our foods safety plan and have added CCP to cooking and was wondering if it is required to have a CCP for cooling if it is not ready to eat?

 

Our current operation involves cooking a batch of filling (sauce filling for chicken pot pies), cooling it in pails and then portioning it into pie tins with pie tops to be vacuum sealed and packed. One problem we are having is that our filling takes over 20 hours to hit 4°C from 80°C. We do not have the capacity in our walk-in freezer as we are in a commissary kitchen. 

 

We have sent micro samples out to prove that there is no risk of micro right now with our the filling is cooled and the product is labelled as NRTE (customers are provided cooking instructions).

 

May i take out cooling as a CCP and just put it in as a CP knowing that we dont have a risk?

 

Thank you!
 

Hi FV,

Seems a possible case of false labelling albeit legally pragmatic.

Are you aware that chilled, cooked, vacuum packed food (regardless of labelling) has the potential for C.botulinum generation ?

Hi!

 

I work with a newly established company in Canada that makes frozen vegan meals in individual servings (like Michelina's line of product).

 

We are currently establishing our foods safety plan and have added CCP to cooking and was wondering if it is required to have a CCP for cooling if it is not ready to eat?

 

Our current operation involves cooking a batch of filling (sauce filling for chicken pot pies), cooling it in pails and then portioning it into pie tins with pie tops to be vacuum sealed and packed. One problem we are having is that our filling takes over 20 hours to hit 4°C from 80°C. We do not have the capacity in our walk-in freezer as we are in a commissary kitchen. 

 

We have sent micro samples out to prove that there is no risk of micro right now with our the filling is cooled and the product is labelled as NRTE (customers are provided cooking instructions).

 

May i take out cooling as a CCP and just put it in as a CP knowing that we dont have a risk?

 

Thank you!
 

Probably not. What kind of sauce is it. Saying it is NRTE and having cooking instructions won't get you past most requirements.

Everything you need to know and follow can be found here

https://inspection.c...9/1522948254134

While I see you've posted that your product is vegan, my suggestion is that you follow these parameters

The reason you cannot chill in a reasonable amount of time is that the container your putting the filling into is too large   Try using sheet pans or similar to reduce the overall volume so that the product can chill faster

If you cannot change your process, consider changing your location as you are asking for spoilage by taking an extreme amount of time to chill your product.  At the very least, your going to lose shelf life, at worst, your going to have contaminated product

Everything you need to know and follow can be found here

 

https://inspection.c...9/1522948254134

 

While I see you've posted that your product is vegan, my suggestion is that you follow these parameters

 

The reason you cannot chill in a reasonable amount of time is that the container your putting the filling into is too large   Try using sheet pans or similar to reduce the overall volume so that the product can chill faster

 

If you cannot change your process, consider changing your location as you are asking for spoilage by taking an extreme amount of time to chill your product.  At the very least, your going to lose shelf life, at worst, your going to have contaminated product

Hi Scampi,

It's a fascinating reference but perhaps a bit of a cop-out in that it seems to not specifically recommend anything. Offhand, I would imagine that most safety-related texts will go nowhere near the first option.

People without blast freezers should probably stay well away from this kind of business.

Another option to try and cool if you can. A type of cold water bath system. In the soup world - this is done. We have 3 lb soups sealed then go through a cold water chill tank first then put into a cooler.

I hate to say it but the person who over saw the product development and the building design - didn't think everything through or didn't know what they were doing. I've seen this happen.

It absolutely displays actual requirements Charles

The word MUST is legally binding 

During cooling, the product's maximum internal temperature must not remain between 54°C and 27°C for more than two (2) hours nor from 54°C to 4°C for more than 7 hours.

Alternatively, products consisting of a piece of intact (excluding tenderized) muscle such as roast beef, moist cooked beef, turkey breast or pork loin, may be cooled to 4°C within 7.5 hours from the initiation of the cooling process while taking no more than two hours for the 50°C to 20°C temperature zone.

The following US Food Safety Inspection Service cooling parameters (as per compliance guidelines in Appendix B, 1999) may also be used for the rapid cooling of ready-to-eat meat and poultry products provided that:

• During cooling, the product's maximum internal temperature does not remain between 130°F (54.4°C) and 80°F (26.6°C) for more than 1.5 hours nor between 80°F (26.6°C) and 40°F (4.4°C) for more than 5 hours. This cooling rate can be applied universally to cooked products (e.g., heat treated or fully cooked, intact or non-intact, meat or poultry) and is preferable to option (2) below.
• The chilling of cooked products begins within 90 minutes after the cooking cycle is completed. All products should be chilled from 120°F (48.8°C) to 55°F (12.7°C) in no more than 6 hours. Chilling should then continue until the product reaches 40°F (4.4°C). The product should not be shipped until it reaches 40°F (4.4°C).

For both options, the cooling between 120°F (48.8°C) and 80°F (26.6°C) does not take more than 1 hour, and chilling must continue between 55°F (12.7°C) and 40°F (4.4°C).

It absolutely displays actual requirements Charles

 

The word MUST is legally binding 

Rapid cooling

During cooling, the product's maximum internal temperature must not remain between 54°C and 27°C for more than two (2) hours nor from 54°C to 4°C for more than 7 hours.

Alternatively, products consisting of a piece of intact (excluding tenderized) muscle such as roast beef, moist cooked beef, turkey breast or pork loin, may be cooled to 4°C within 7.5 hours from the initiation of the cooling process while taking no more than two hours for the 50°C to 20°C temperature zone.

The following US Food Safety Inspection Service cooling parameters (as per compliance guidelines in Appendix B, 1999) may also be used for the rapid cooling of ready-to-eat meat and poultry products provided that:

• During cooling, the product's maximum internal temperature does not remain between 130°F (54.4°C) and 80°F (26.6°C) for more than 1.5 hours nor between 80°F (26.6°C) and 40°F (4.4°C) for more than 5 hours. This cooling rate can be applied universally to cooked products (e.g., heat treated or fully cooked, intact or non-intact, meat or poultry) and is preferable to option (2) below.
• The chilling of cooked products begins within 90 minutes after the cooking cycle is completed. All products should be chilled from 120°F (48.8°C) to 55°F (12.7°C) in no more than 6 hours. Chilling should then continue until the product reaches 40°F (4.4°C). The product should not be shipped until it reaches 40°F (4.4°C).

For both options, the cooling between 120°F (48.8°C) and 80°F (26.6°C) does not take more than 1 hour, and chilling must continue between 55°F (12.7°C) and 40°F (4.4°C).

Hi Scampi,

Can compare the ^^^reds, they are mutually contradictory (possibly also related to [unstated] varying PC characteristics such as product size, fat levels, etc) . The article is an excellent survey of cooling time  "opinions" but  which one is to be preferred ? The (4th) most conservative[?] Blue one ?

For large size meat objects, IIRC, "relatively" slow cooling is operationally (and theoretically) unavoidable  but this is, or should be (eg Posts 4, 6), a different situation to the OP.

USDA previously published some useful, detailed, practical setups to enable compliance with Guidelines such as mentioned in yr link but I think they all assumed that a blast freezer was available. Attached on this Forum (somewhere).

PS - the quoted link to the famous Appendix B sadly doesn't go there anymore.