Is it ready-to-eat (RTE)? How do you know?

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1 Is it ready-to-eat (RTE)? How do you know? 79TH ANNUAL SEAFOOD PROCESSORS WORKSHOP March 9, 2017 Bell Harbour Conference Center 2211 Alaskan Way, Pier 66 Seattle, WA 98121 Charles M. Breen CMBREEN LLC CHARLES.BREEN@OUTLOOK.COM

2 Are frozen vegetables RTE?

3 Not a theoretical problem May 6, 2016 At least six nationwide Listeria recalls have been issued this week as the list expanded again Friday. Certain brands of frozen vegetables, granola bars and sunflower seeds have been recalled... In each recall, the product was contaminated with Listeria monocytogenes.

4 Recalled for E coli O121 April 2013 A total of 35 persons infected with the outbreak strain of Shiga toxinproducing Escherichia coli O121 (STEC O121) were reported from 19 states. 82% [29] of ill persons were 21 years of age or younger. CDC report, May 30, 2013

5 Are cooking instructions enough?

6 Are cooking instructions enough? What would a child, or an inebriated young man be more likely to do? Bake at 450 0 F for 13 minutes? Or microwave for 2 minutes?

7 Frozen fish sticks

8 Nestle Cookie Dough, before & after recall

9 ConAgra label after 2007 Salmonella recall

10 Revised Food CGMP: 117.3 Definitions. Ready-to-eat food (RTE food) means any food... normally eaten in its raw state or any other food... for which it is reasonably foreseeable that the food will be eaten without further processing that would significantly minimize biological hazards. (Translation: properly cooked)

11 Who decides, manufacturers or consumers? just like chipotle s corn salsa Ingredients: 1-12-ounce bag of frozen yellow corn, defrosted and drained 2 medium-sized jalapenos, seeded and chopped (leave in some seeds for more heat if desired) 1/2 red onion, finely chopped (about 1/3 cup) 3/4 cup fresh cilantro, torn or chopped... Directions: Combine all ingredients in a bowl and mix, mix, mix. Season with additional salt and pepper if desired. Add more cilantro, jalapeno or lime according to your tastes!

12 Mommy blogs More Mom-Tested Teething Tricks We used frozen crinkle-cut French fries. Whenever... we knew that a new tooth was coming through, we would grab one fry from the fridge and let him chew on it. M. M., Omaha, NE

13 Is this a food? Home made Play Dough Ingredients 3 cups flour 1 cup cold water 1 cup salt 2 teaspoons oil Food coloring or powdered paint Mix it all together in a bowl keep kneading it until it s just right. You can even a touch of vanilla or peppermint to make it smell wonderful!

14 Some degree of rodent filth in wheat flour is inevitable Defect Action Level: The FDA set these action levels because it is economically impractical to grow, harvest, or process raw products that are totally free of nonhazardous, naturally occurring, unavoidable defects. Products harmful to consumers are subject to regulatory action whether or not they exceed the action levels. https://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/sanitation Transportation/ucm056174.htm

15 Defect Action Level (DAL) Wheat Rodent filth Average of 9 mg or more rodent excreta pellets and/or pellet fragments per kilogram Wheat Flour Rodent filth Average of 1 or more rodent hairs per 50 grams

16 FDA draws a clear line: Eating raw dough or batter... for bread, cookies, pizza or tortillas could make you, and your kids, sick, says Jenny Scott, a senior advisor in FDA s Center for Food Safety and Applied Nutrition.... Why? Flour... can contain bacteria that cause disease. (June 28, 2016)

17 Seafood is exempt from FSMA preventive controls if in compliance with Part 123

18 FDA draws a fuzzy line: Eating Raw Seafood -What You Need To Know It's always best to cook seafood thoroughly.... However, if you choose to eat raw fish anyway,... eat fish that has been previously frozen.... freezing will kill any parasites that may be present. However, be aware that freezing doesn't kill all harmful microorganisms. That's why the safest route is to cook your seafood. (Aug 15, 2016) https://www.fda.gov/food/resourcesforyou/consumers/ucm077331.htm

19 This relates to FSMA how? CGMPs require proper equipment, cleaning, and maintenance. PCHF mandates hazard analysis, hazard controls, validation, and verification. RTE food must include environmental monitoring as a verification measure.

20 What s going on?

21 To make a dimpled surface

22 Welding repairs Photo 5, a flat plate welded on one side without backer rod - depression is a hiding place for microbes and soils. Photo 6, plate is welded with backer rod but not ground and polished a food safety risk. Photo 7, a ground and polished sanitary weld.

23 3A SSI, dairy industry standards Food Product Contact Surfaces are: Smooth, Impervious, Free of cracks and crevices, Nonporous, Nonabsorbent, Non-contaminating, Nonreactive, Corrosion resistant, Durable and maintenance free, Nontoxic, and Cleanable.

24 American Meat Institute 10 Principles of Sanitary Design (2003) Cleanable to a microbiological level Made of compatible materials, Accessible for inspection, maintenance, cleaning and sanitation without the use of tools, No product or liquid collection, Hollow areas hermetically sealed, No niches, Sanitary operational performance, Hygienic design of maintenance enclosures, Hygienic compatibility with other plant systems, Validated cleaning and sanitizing protocols.

25 How RTE food processor should buy equipment:

26 Questions?