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Recording and Immersion Temp Discussion
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Recording and Immersion Temp Discussion
Hey all, here is the link to the recording for December’s meeting: https://youtu.be/NBdRheGpSlk
Also, below is the response that Stasia received from Laura Strawn at Virgina Tech, which was discussed during the meeting.
Wishing all of you the best as we turn back towards the light!
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1) EMP + APC thresholds
Short answer: there isn’t a regulatory or HGAP+ “magic number” for APC. FSMA/PSR doesn’t prescribe indicator limits for environmental programs; HGAP+ requires you to define your acceptable results and corrective actions based on risk and trending (not a universal CFU cutoff). The industry norm for produce packinghouses is to target Listeria spp. in Zones 2–4 for the EMP and use ATP or visual + sanitation verification for routine pre-op checks; APC is optional and, if used, should be managed with site-specific alert/action levels based on your baseline rather than a canned value. AMSIAFP
What I recommend for your chart (edits in CAPS):
- Facility Water –
Generic E. coli &
Total Coliforms: “Not Detected by the method” (or <DL) at the stated frequency. Keep this as written. Aligns with PSR concepts and
HGAP+. eCFRAMS - Zone 2 (incidental food-contact: framework/overheads, etc.) – Replace APC with:
- Primary:
Listeria spp. (post-op while running) –
Not Detected. - Sanitation verification (pre-op):
ATP
with site baseline (e.g., set alert/action from your own RLU
distribution). Rationale: this zone is where early Listeria finds show
up; ATP tells you if cleaning actually removed soils.
No published APC limits exist for this purpose. International Fresh Produce AssociationIAFP
- Zone 3 / Zone 4 – Keep
Listeria spp. (or
Salmonella/indicator where appropriate) as
Not Detected with the frequencies you listed. That matches fresh-produce guidance and HGAP+.
International Fresh Produce AssociationAMS- Compressed Air – If air can contact food or food-contact surfaces, reference
ISO 8573-7 for
how to test, and set an internal spec of
“No detected coliforms/E. coli” and
very low total count
based on your baseline. (There is no universal CFU/mL or CFU/m³ limit
in produce—standards point to method, not a number.) Add point-of-use
filtration where feasible.
Compressed Air Best PracticesTrace Analytics, the AirCheck Lab+1If you want numeric starting points for internal policy (not audit gospel): use your history (most results ?30 CFU/mL) to set Alert ?100 and Action ?1,000 CFU/mL for any APC you still choose to run. Flag anything trending upward even below those. Then tighten once you’ve trended a month or two. That “trend-based” approach is exactly what auditors expect under HGAP+. AMS
2) Water temperature control (apples; infiltration risk) =
https://www.afdo.org/wp-content/uploads/2024/05/AFDO-Susceptibility-of-Produce-to-Infiltration-from-Harvest-and-Postharvest-Water-Resource.pdf = this is my new
resource here – you are golden!Core science: Infiltration happens when warm fruit goes into cooler water. The pressure drop inside the fruit pulls water (and microbes) in through the stem/calyx. To reduce risk, keep immersion/dump water warmer than the fruit—common industry guidance is warmer water than pulp. U.S. Food and Drug Administrationpsdocs.spes.vt.eduCornell Agricultural Sciencesncfreshproducesafety.ces.ncsu.edu
- Your numbers: apples ~42°F; water
62–67°F (drops to ~62°F when a cold bin is added). That’s
+20–25°F warmer than fruit—even after the drop you’re
+20°F.
This is favorable (no infiltration trigger).
U.S. Food and Drug Administration
- What HGAP+ will look for: Written SOP stating you control immersion water temp
when the commodity is susceptible, and records showing you check it (you’re already logging twice per day with PAA—great). The standard tells you to control temp
per current industry standards;
it doesn’t impose a single number. Your SOP can say “maintain immersion water warmer or
above apple pulp temperature; if differential is
<10°F (or set a different number – I hate a fast and hard number but you are such a big gap) or water becomes
colder than pulp,
pause and correct.”
AMS
- PSR tie-in:
21 CFR 112.48(c) requires maintaining/monitoring water temperature
“appropriate for the commodity and operation.” Your warmer criterion is a
defensible interpretation aligned with FDA guidance on infiltration and
the AFDO document – fda approved
SOP language you can paste:
- Target: Keep dump/immersion water
warmer than apple pulp temperature during immersion steps. - Monitoring: Record
pulp temp (start of shift, mid-shift) and
water temp (with each sanitizer test or min.
2×/day). - Corrective action: If water ? pulp temp,
stop immersion, adjust with tempered make-up water or allow fruit to equilibrate, re-verify, document action. **or see AFDO document for ideas
- Verification: Weekly review of logs + calibration checks of thermometers.
(For peaches/pears: same infiltration principle applies when those commodities are immersed; if they don’t go through immersion, note “N/A” with justification.) – hydrocooler?
Quick disposition on your original APC “<3000 CFU/mL”
- It’s not anchored to a produce-industry standard I can find. I’d
replace it with the risk/trend framework above and emphasize
Listeria spp.
as the EMP organism for Zones 2–4, ATP for pre-op hygiene, and ISO
8573-7 for compressed air testing method. That will read much stronger
to an HGAP+
- Facility Water –
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