Critical Limit

[Nishad Hussain]

Dear All,

One of my friend working in a catering company which is located in Abu Dhabi. He asked me about one doubt and we discussed it and we both have different opinon. Please help me to clarify the doubt with scientific evidences.

In ADFCA regulation 6, 2010 Article 30 says "chilled foods should keep below 5 degree Celsius and frozen food should keep below -18 degree Celsius". But in article 38 says "if the temperature of the chilled food at any time is above 5 degree Celsius and below 8 degree Celsius, the food shall be immediately chilled to 5 degree Celsius". And in article 39 says for frozen foods "if the temperature at any time is -15 degree Celsius to -18 degree Celsius, food shall bought to minimum of -18 degree Celsius as rapidly as possible".

They identified chilled and frozen storage as their CCP. 

My question is what is this 8 degree Celsius and -15 degree Celsius called? Some says its critical limit some says it's CCP Value, tolerant value etc. Please clarify me whether Critical limit should be 0 to 5 degree Celsius for chilled storage and below -18 degree Celsius for frozen foods? Or critical limit should be 8 degree Celsius for chilled storage and below -15 degree Celsius for frozen storage?

Kind Regards

 

 

Nishad Hussain

Assistant Training Manager

Intercat Hospitality LLC

Dubai

[Mohammed Thasreef]

Dear Nishad,

With all the different standards and legal requirements by different bodies its understandable to have a confusion regarding this.

A food temperature of 8°C or below is effective in controlling the multiplication of most bacteria in perishable food. It is recommended practice to operate refrigerators and chills at 5°C or below. (Ref: https://www.food.gov.uk/sites/default/files/multimedia/pdfs/cshrtempcontrol.pdf)

Your Question 

"My question is what is this 8 degree Celsius and -15 degree Celsius called?”

Ans: Nothing I guess.

I believe you get CCP. The value above or below, where the product is acceptable or not acceptable. (e.g.: 1-5 degrees for chiller)

Target Limit is more strict. To make sure there is no deviation. (e.g.: 0-3 degrees)

Deviation is crossing the CL. (e.g.: 5 degrees and above)

How ever some local bodies do give a little bit of a "TOLERANCE LIMIT”, which shall not be more than 3 degree celsius from the critical value.

Hence 5+3=8 degree.

Now, if you run a strict business and a strong policy, and when you check the temperature of your “PRODUCT” not “CHILLER” and notice it to be more than 5 degrees , you could discard it, considering its already deviated from the CCP (Hence not acceptable). Or you could take the leniency given by the local bodies and cool it immediately down to 5 and below and relax (only if it is still 8 or below).

Same goes to the freezer. Hence -18+3=-15 degrees.

Your question:

Or critical limit should be 8 degree Celsius for chilled storage and below -15 degree Celsius for frozen storage?

Ans: If you set 8 as the CCP and you get a reading of 6 degrees you break article 30. 

The Article 38 means “If you break Article 30 and has not gone so far (8 degrees) take a CORRECTIVE ACTION. Which is what we do when the CCP deviates.But the product is acceptable only if you haven’t crossed 8 degree, if you did, unless you have a scientific evidence, discard it."

I hope I make sense. If not, i call out to the more experienced ones to help me and my friend out here.

Thank you.

--
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[Bobby Krishna]

Mohammed,

Gone are the days when 5 or 8 Deg C was a 'golden' rule and anyone could frame their internal monitoring temperatures based on the government recommendations. Today, you might have to go below the recommendations because outbreak data tells you that Listeria M is increasingly becoming a concern with the popularity of cold meat. Reduction in salt (raising the nutrition concern) could also be another reason why refrigeration temperature should be lowered.

While writing the Food Code for Dubai, we kept 5 C as it's an internationally recognised benchmark except for the UK where it is 8 C (Listeria and Salmonella can multiply slowly at this temperature). UK also has a hot food storage temperature of 63 C (which is 11 degrees higher than the temperature at which any pathogen can grow).

I contacted several experts in the UK and they couldn't justify this 63 C when US requires 57 C.

The only reason we could workout is that since it's a cold country, cold food would stay colder than 8 C for most months because of the low ambient temperature and Hot food would run colder faster (requiring a higher temperature to accommodate the deviation). Well, that perhaps is the 'regulatory buffer' to ensure that deviation doesn't cause an outbreak.

Logically, in a hot country the logic should be the other way round. Cold food should be held at a temperature lower than in the U.K. It would also mean that hot food would become colder slower in a warm environment and 60 or 57 C would be good enough not to dry the food out. That is the logic we have used and we have explained this in the Food Code.

Having said this, CCPs should not be dependent on the regulatory requirement alone. 

- if you have fish that is used for sushi, it must be at around 2 C to ensure it doesn't get contaminated 

- if you have vacuum packed cold foods, hitting 8 C is a risk 

- if you have a product that can harbour Listeria, you need to get the temperature as low as possible.

Moreover, you should always have a target CCP temperature lower than the regulatory limit so that you don't break the law.

On the other hand, -18 C for frozen foods is a 'quality' requirement. Pathogens are not a concern. Ice creams are stored at -12 C.

Defrosting is a ¯Quality risk and as log as you are above -10, you are safe. 

Don't forget that the only reason -18C is a gold standard is because it is same as 0 Deg F which was preferred for American standards for equipment.

So, don't do HACCP without looking at the logic. Use Combase.cc to work out the temperature and time models and see what's the best for your product based on the nature of the product. 

Bobby Krishna

Sent from i Phone

[Bobby Krishna]

Answer:

//My question is what is this 8 degree Celsius and -15 degree Celsius called? Some says its critical limit some says it's CCP Value, tolerant value etc.//

Depends on how you define it in your manual. If you are using it as a Critical Limit, then both time and temperature have to be defined.

//Please clarify me whether Critical limit should be 0 to 5 degree Celsius for chilled storage and below -18 degree Celsius for frozen foods? Or critical limit should be 8 degree Celsius for chilled storage and below -15 degree Celsius for frozen storage?//

A critical limit has to be a 'limit' and not a range. So, if you decide it at 5, the product has to be discarded if it hits 6. However, of you say the limit is not to exceed 5 Deg C for more than 20 Minutes post process, it's a lot more practical.

However, traditional approaches do not mention time and everyone tries to say 'it's just a short exposure while we got the delivery.' While I still say that food has to be delivered below 5 C, post delivery handling has to be accommodated in to the Haccp plan as well and time accounted for.

If you read the Food Code carefully, we have allowed certain deviation too. Unfortunately, this has not found a place in the HACCP manuals yet. We still use the Manufacturing industry type Critical Limits that are often too difficult for catering.

Bobby Krishna
Sent from i Phone

[Thashreef]

Thank you for your feedback. All of it makes sense. Then again, I was merely aswering the question. The question which was based on the " Government regulations". 

Thank you for the new info on why 63 is used. Didnt know that. 

Thank you. 

--

Mohammed Thasreef
Food safety trainer
GEMS QUALITY CONSULTANTS
DEV. BOARD BUILDING
Damascus Street 4
DUBAI.
0555-25-7006

[Rex Dasan]

Hi Niashad 

Here is a useful link for you, which explains the definition a the "Critical limit" very clearly.

 

https://myhaccp.food...critical-limits

  Regards 

Rex