Chilled Food Audit Requirements

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• Chilled Food Audit Requirements
• Whats Critical
• Kaarin Goodburn
• Chilled Food Association
• cfa_at_chilledfood.org
• www.chilledfood.org
• IFST, 13/10/11

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• The unique UK chilled prepared food sector, CFA
• Standards and certification
• Best practice
• Key principles
• How to decide what hygiene standards apply
• Legislation
• Whats critical in auditing chill summary
• CFA Guidance

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UK Retail Chilled Prepared Food Industry
Year Market (m)
1989 550
1999 4550
2005 7357
2010 9163

• Chilled foods unique position
• Predominantly UK-made - Very few finished product
  imports
• Unpreserved
• Just in time
• HACCP from the outset
• Exacting microbiological standards
• Significant annual new product development
• Retail brand dominance, although brands now
  emerging

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UK Chilled Prepared Food Characteristics

• Mainly multicomponent
• Complex ingredient streams
• Animal derivatives content 0-100, large
  proportion of foods 5-25
• Remainder carbohydrate, e.g. bread, pasta,
  produce
• Potential for re-working generally low
• Much is handmade
• Short shelf life ingredients and final products
• Ingredient replenishment in line with projected
  orders
• Rapid distribution for sale
• Specified suppliers, own/contract growers
• Integrated control high risk ingredients not
  bought on open market
• Largely ready to eat
• Hygiene is critical

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What Are Chilled Foods?
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UK Chilled Prepared Food

• Dressed salads
• Leafy salads
• Prepared Vegetables
• Prepared fruit
• Stir fry kits
• Sandwiches
• Sandwich fillings
• Quiche/flans

• Pizza
• Recipe dishes/kits
• Meal Accompaniments
• Sushi
• Filled fresh Pasta
• Soups (some RTE)
• Sauces (some RTE)
• Desserts

Items in green include ready to eat
variants Leafy salads (1990) UK 2.7 x109
packs, Worldwide 2x1010 packs
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Chilled Food Association

• Who are we?
• Represent professional manufacturers supplying UK
  market
• What is our Mission?
• To promote and defend the reputation and value of
  the professional chilled food industry through
  the development and communication of standards of
  excellence in the production and distribution of
  chilled food

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CFAs Overall Strategy

• Promote CFA standards and the sector to
  regulatory bodies, policymakers and other
  stakeholders
• CFA Members promote CFA standards throughout
  their supply bases
• CFA catalyses action on issues broader than the
  chilled food sector alone
• Aims to attract members who
• Are professional chilled food manufacturers and
  chilled component/raw material suppliers
• Meet CFA Guidelines standards
• Are certificated to appropriate technical
  standards

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Standards Certification

• CFA is founded on Standards and certification
• CFA membership requirements
• Statement of compliance with CFAs Guidelines
• Supporting reference from an existing member
• Corroborative competence information
• BRC or IFS certificate non-conformances and
  close-outs
• CV of the person responsible for food safety
• 14/12/89 Minister for Food Safety, David Maclean
• First edition CFA Guidelines Accreditation
  Scheme
• BRC endorsement ? aspired reduction in audits
• launched created at CFAs request
• Who audits the auditor?

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Enforcement Layers Own Label Chilled Food

• Food safety management system internal audit
• And day to day management
• Customer (retailer) audit
• And interim visits
• Third party audit
• e.g. BRC (corrective action within 28d)
• Environmental Health visit
• Frequency based on scoring

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CFA Best Practice Production Guidelines

• CFA Guidelines
  Recommendations
• hygiene area terminology differs but standards
  are the same
• CFA Guidelines publicly endorsed by major
  retailers at senior technical level

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Key Principles RTE, RTRH, RTC

• Ready to Eat (RTE)
• Intended by the producer or the manufacturer for
  direct human consumption without the need for
  cooking or other processing effective to reduce
  to an acceptable level or eliminate
  microorganisms of concern. (cold-eating) 
• Ready to Cook (RTC)
• Designed to be given a heat process delivering a
  6-log kill with respect to vegetative pathogens
  (a minimum process equivalent to 70C/2 mins)
  throughout all components
• Ready to Reheat (RTRH)
• Manufactured in a High Care or High Risk Area and
  is designed to be reheated by the final consumer

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Key Principles Hygiene

• Specified high quality raw materials
• Complete cooked/uncooked materials segregation
  3 hygiene areas
• Cooking Processing to achieve minimum 6 log
  reduction of target organism
• 3 Hygiene Areas
• High Risk (ECFF cooked HCA/cHCA)
• High Care (ECFF raw HCA/rHCA)
• Low Risk/GMP (ECFF LRA)
• Other products must not be produced in a HCA
  unless HACCP shows there are no additional risks
  to all products

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Key Principles Manufacturing Hygiene Areas

• Low Risk Area
• Raw material intake, ready to cook foods,
  packaged product
• Separate equipment, utensils, staff and changing
  areas
• High Care Area (raw HCA)
• RTE and RTRH food production
• Includes RTE/RTRH ingredients not thermally
  processed (minimum 70C/2) but having been
  decontaminated (validated) and grown/produced to
  RTE standards
• Separate equipment, utensils, staff and changing
  areas
• High Risk Area (cooked HCA)
• RTE and RTRH food production
• Only thermally processed foods (minimum 70C/2)
• Separate equipment, utensils, staff and changing
  areas

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• How to decide what hygiene standards apply

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• CFA decision tree determines the standard
• thermal process used
• risk presented by the manufacturing environment
  to the product

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Equivalent thermal process Micro effect of thermal process Post-process contam risk? Remaining hazards to be eliminated or controlled Min hygiene level reqd
All components ? 70C/2 equiv? YES ? Vegetative pathogens (e.g. Listeria spp.) destroyed. C. botulinum B. cereus potential hazard ? YES ? Strict hygiene. Hurdles v. C. botulinum must be used to achieve gt10d ? HRA
All components ? 70C/2 equiv? YES ? Vegetative pathogens (e.g. Listeria spp.) destroyed. C. botulinum B. cereus potential hazard        
All components ? 70C/2 equiv? YES ? Vegetative pathogens (e.g. Listeria spp.) destroyed. C. botulinum B. cereus potential hazard ? NO ? C. botulinum B. cereus potential hazard. Hurdles v. C. botulinum must be used to achieve gt10d ? LRA
NO         Cook before consuming?      
Not all components ? 70C/2 equiv? YES ? All types of pathogens remain a hazard NO ? (RTE, RTRH) Pathogens may remain from original components or recontamination. Limit further contamination by using HCA. Shelf life may need to be short unless sufficient hurdles used ? HCA
Not all components ? 70C/2 equiv? YES ? All types of pathogens remain a hazard        
Not all components ? 70C/2 equiv? YES ? All types of pathogens remain a hazard YES ? (RTC) Pathogens may remain from original components or recontamination. Cooking instructions must be validated. Shelf life may need to be short unless sufficient hurdles used ? LRA
Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products  
equivalent heat treatment during processing   Effect of heat treatment   Risk of contamination?   Remaining hazards to be eliminated or controlled   Minimum hygiene level required
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• How should the decision tree be used?
• Examples
• Ready to reheat lasagne
• Ready to eat mixed leaf and veg salad
• Ready to cook pizza

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Fully Cooked RTE/RTRH Food e.g. RTRH Lasagne
Equivalent thermal process Micro effect of thermal process Post-process contam risk? Remaining hazards to be eliminated or controlled Min hygiene level required
All components ? 70C/2 equiv? YES ? Vegetative pathogens (e.g. Listeria spp.) destroyed. C. botulinum B. cereus remain a hazard ? YES ? Control recontamination by strict hygiene. Hurdles against C. botulinum must be used to achieve shelf life gt10d ? HRA
All components ? 70C/2 equiv? YES ? Vegetative pathogens (e.g. Listeria spp.) destroyed. C. botulinum B. cereus remain a hazard        
All components ? 70C/2 equiv? YES ? Vegetative pathogens (e.g. Listeria spp.) destroyed. C. botulinum B. cereus remain a hazard

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Raw RTE Food e.g. Mixed Leaf Veg Salad
Equivalent thermal process
All components ? 70C/2 min equivalent?
All components ? 70C/2 min equivalent?
All components ? 70C/2 min equivalent?
NO    Micro effect of thermal process  Cook before consuming? Remaining hazards to be eliminated or controlled Min hygiene level required
Not all components ? 70C/2 min equivalent? YES ? All types of pathogens remain a hazard NO ? (RTE) Pathogens may remain from original components or recontamination. Limit further contamination by using HCA. Shelf life may need to be short unless sufficient hurdles used ? HCA
Not all components ? 70C/2 min equivalent? YES ? All types of pathogens remain a hazard        
Not all components ? 70C/2 min equivalent? YES ? All types of pathogens remain a hazard
Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products   Figure 1 Decision tree to determine the minimum hygienic status required for chilled products  
equivalent heat treatment during processing   Effect of heat treatment   Risk of contamination?   Remaining hazards to be eliminated or controlled   Minimum hygiene level required
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RTC Food, e.g. Pizza
Equivalent thermal process
All components ? 70C/2 min equivalent?
All components ? 70C/2 min equivalent?
All components ? 70C/2 min equivalent?
NO     Micro effect of thermal process   Cook before consuming? Remaining hazards to be eliminated or controlled     Min hygiene level required
Not all components ? 70C/2 equiv? YES ? All types of pathogens remain a hazard
Not all components ? 70C/2 equiv? YES ? All types of pathogens remain a hazard        
Not all components ? 70C/2 equiv? YES ? All types of pathogens remain a hazard YES ? (RTC) Pathogens may remain from original components or recontamination. Cooking instructions must be validated. Shelf life may need to be short unless sufficient hurdles used ? LRA
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Legislation

• RTE Foods EU Reg 2073/2005 FSA/CFA/BRC guidance
  
• Environmental monitoring for Lm (or Listeria spp)
• Shelf life protocol to be followed
• Evidence of no exceedance of 100 Lm/g during
  shelf life
• EC Reg 2000/13 requires labelling of usage
  instructions
• Reheating or cooking instructions must therefore
  provided on non-RTE foods
• Ready to Cook
• Cooking heating by the consumer so that all
  parts of a food or food ingredient reach a min
  time/temperature equivalent of 70C for 2 mins,
  i.e. a 6-log reduction of Lm
• Validated preparation instructions to assure that
  these times and temperature requirements are met

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Whats Critical in Auditing Chill?

• Standards are appropriate, i.e.
• Management of supply chain inc traceability
• e.g. Raw RTE ingredients grown/produced to RTE
  standards
• Personnel measures implemented
• Pre-employment screening
• Training
• Return to work rules
• Manufacturing hygiene management robust
• Area segregation in place
• Thermal processing validated
• Environmental monitoring in place and acted on
• Final product sampling in place and acted on
• Post-manufacture
• Shelf life controlled and based on chill chain
  performance and Lm
• Cooking instructions validated
• Chill chain functioning
• Auditors are competent to make assessments

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Key CFA Guidelines

• Primary production
• Microbiological Guidance for Growers
• Pesticides Due Diligence
• Veterinary Residues Management Guidance
• Factory
• Best Practice Guidelines for the Production of
  Chilled Food
• Covers all chilled prepared foods
  www.tsoshop.co.uk/chilledfoods
• Hygienic Design Guidelines
• Multicultural Hygiene Training
• Produce washing protocols
• General
• Water Quality Management Guidance
• Guidance on the use interpretation of micro
  testing
• Guidance on the Practical Implementation of the
  EU Micro Criteria Regulations (FSA-endorsed
  CFA/BRC )
• Lm and shelf life guidance (CFA/BRC/FSA)

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• The centre of excellence for the chilled food
  industry
• www.chilledfood.org