HACCP: Considerations for High Risk Processes

An important consideration when assessing food safety plans is whether the organization is handling potentially hazardous foods in their operation.

Potentially Hazardous Foods (PHF) definition

The Food Standards Code 3.2.2 –defines a potentially hazardous food as:

Food that has to be kept at certain temperatures to minimise multiplication of any food-poisoning bacteria that may be present in the food, or to prevent the formation of toxins in the food.

Foods that are not potentially hazardous (generally inhibitory to pathogens by way of low Ph and/or low water activity, and/or use of additives such as high salt, high alcohol, preservatives, etc)

Dry goods, unopened canned foods
Pickles, sauces - ketchup style
Salad dressings sauces - Asian/Soy
Bottled marinades & salsas
Bottled pasta sauces
Raw whole fruit and vegetables
Nuts in the shell, dried fruit
Salted dried meats, fermented dried meats
Honey and jam, peanut butter
Fruit cake, plain cakes
Biscuits and crackers, plain breads and bread rolls
Hard cheeses, yoghurts
Fruit juices, confectionary

Foods that are potentially hazardous (generally more neutral pH, high water activity)

Raw or cooked meat including poultry or game
Foods containing raw or cooked meat casseroles, curries, lasagne
Smallgoods, devon, ham, chicken loaf
Dairy products- milk, custard, dairy desserts, unbaked cheesecake, custard tarts
Seafood (excluding live seafood)- seafood salad, soup, fish sticks, stews
Processed fruit and vegetables, salads, cut melons
Cooked pasta and rice
Foods containing eggs, beans, nuts or other protein-rich foods
Quiche, fresh pasta, soy bean products
Foods containing the above foods, sandwiches, rolls, uncooked and cooked pizza
Whole raw eggs (not listed in the NSWFA document, however it is regarded by FDA as a PHF)

Receival- are PHF’s being received?

FSANZ 3.2.2-, 5 (3)- A food business must, when receiving potentially hazardous food, take all practicable measures to ensure it only accepts potentially hazardous food that is at a temperature of

(a) 5°C or below; or

(b) 60°C or above,

unless the food business transporting the food demonstrates that the temperature of the food, having regard to the time taken to transport the food, will not adversely affect the microbiological safety of the food.

Storage- are PHF’s being stored

FSANZ 3.2.2, 6 (1) & (2). A food business must, when storing or displaying potentially hazardous food

(a) store it under temperature control; and

(b) if it is food that is intended to be stored frozen, ensure the food remains frozen during storage.

temperature control means maintaining food at a temperature of –

(a) 5°C, or below if this is necessary to minimise the growth of infectious or toxigenic microorganisms in the food so that the microbiological safety of the food will not be adversely affected for the time the food is at that temperature; or

(b) 60°C or above; or

(c) another temperature - if the food business demonstrates that maintenance of the food at this temperature for the period of time for which it will be so maintained, will not adversely affect the microbiological safety of the food.

Heat Process- are PHF’s being subjected to a pathogen reduction step?

From FSC 3.2.2, 7 Food processing.

(1) A food business must –

(a) take all practicable measures to process only safe and suitable food; and

(b) when processing food –

(i) take all necessary steps to prevent the likelihood of food being contaminated; and

(ii) where a process step is needed to reduce to safe levels any pathogens that may be present in the food – use a process step that is reasonably known to achieve the microbiological safety of the food.

(2) A food business must, when processing potentially hazardous food that is not undergoing a pathogen control step, ensure that the time the food remains at temperatures that permit the growth of infectious or toxigenic microorganisms in the food is minimised.

Cook Chill Processes

Definition- Cook Chill

The term used to describe food preservation systems where there is a significant time buffer between food cooking and its consumption. During the intervening period, the food is kept in chilled storage.

Shelf-life (for cook chill products): days from the day of cooking/pasteurising to the Use-by Date.

Note that product cooling and storage time prior to dispatch is included in this time.

From the Cook Chill for Foodservice and Manufacturing (the “Blue Book”)-

Short shelf life, or SSL: up to 10 days
Extended shelf life, or ESL: over 10 days

Primary Target Organisms

SSL: Listeria monocytogenes
ESL: shelf-life at < 3°C, Listeria monocytogenes shelf-life at > 3°C - 8°C, non- proteolytic Clostridium botulinum.

Minimum Heat Process

up to 10-day shelf-life (short shelf life, or SSL): heat to 75°C or equivalent lethality
over 10-day shelf-life (extended shelf life, or ESL): 90°C/ 10 mins or equivalent lethality

Other pathogen reduction or preservation processes

Examples include curing, fermentation, acidification, use of preservatives, humectants, hurdle technology, etc.

Validation references or in-house trials for choice of critical limits must be sound.

Check whether other regulatory requirements might apply e.g.

FS Code for the specific food
NSW Food Authority requirements for sprout producers

Vulnerable Persons requirements

Vulnerable person means a person who is in care in a facility listed below or a client of a delivered meals organisation.

Vulnerable persons business means a food business that processes or serves potentially hazardous food to six or more vulnerable persons in facilities such as:

acute care hospitals, psychiatric hospitals, nursing homes for the aged, hospices, same day establishments for chemotherapy and renal dialysis services, respite care establishments for the aged, same day aged care establishments, low care aged care establishments, delivered meals organisations, and childcare centres (not currently implemented in NSW).

Refer to

Vulnerable persons Food Safety Scheme of Food Regulation 2010
Standard 3.3.1 of the Food Standards Code
NSW Food Authority - Guidelines for food service to vulnerable persons

Cold makeup, refrigerated PHF’s

As there is no kill step, this process would rely on-

Control of ingredients- Approved Supplier Program, Specifications, C of A, etc.
Support programs- cleaning, sanitation of all food contact equipment, food handler hygiene, etc, and their verification
They would need to verify that the final product did not contain pathogens.

Cold storage requirements apply

Cooling of PHF’s

From FSC 3.2.2, 7 (3)-

A food business must, when cooling cooked potentially hazardous food, cool the food –

(a) within two hours – from 60°C to 21°C; and

(b) within a further four hours – from 21°C to 5°C; unless the food business demonstrates that the cooling process used will not adversely affect the microbiological safety of the food.

Note that other references specific to the food may apply e.g. AS 4696 2007 Hygienic Production and Transport of Meat-Meat Products for Human Consumption (Scarm 80)- 24 hour cooling regime.

Note that this could also apply to PHF’s that are being prepared for incorporation into other products e.g cooling of a PHF that is an ingredient for another process.

Freezing/ Thawing- are PHF’s going to be frozen or thawed?

Thawed food is to be used immediately, or stored in the coolroom (for potentially hazardous foods) for no longer than 48 hours.

Do not re-freeze thawed food unless it is safe to do so (thawed food has a limited shelf life because of excessive moisture on the surface will allow more rapid microbial growth).

Post-process storage- are PHF’s being stored?

Refer FSANZ 3.2.2 (1) & (2).

The Australian requirements for the storage and display of potentially hazardous foods are:

• PHF must be stored and displayed below 5°C or above 60°C

• PHF must be thrown out if stored or displayed at temperatures between 5° and 60°C for more than four hours

• PHF must be used immediately if stored or displayed between 5° and 60°C for between two and four hours

• PHF may be either refrigerated or used immediately if stored or displayed at between 5° and 60°C for less than two hours

Food businesses can change these requirements if they demonstrate that some other practice will minimise the growth of pathogenic bacteria and the toxin production by bacteria.

Scientific expertise and laboratory testing is required to demonstrate that any other practice is effective.

Transport- are PHF’s being transported?

FSANZ 3.2.2 (10) Food transportation

A food business must, when transporting food –

(a) protect all food from the likelihood of contamination;

(b) transport potentially hazardous food under temperature control; and

(c) ensure that potentially hazardous food which is intended to be transported frozen remains frozen during transportation

temperature control means maintaining food at a temperature of –

(b) 60°C or above; or

Reheating potentially hazardous food

From Qld Dept of health-

Potentially hazardous food must be reheated rapidly to 60°C or hotter. Ideally, you should aim to reheat food to 60°C within a maximum of 2 hours, to minimise the amount of time that food is at temperatures that promote the growth of bacteria.
It is recommended that previously cooked and cooled potentially hazardous food be heated to a minimum of 70°C for at least 2 minutes.
Potentially hazardous food that has already been reheated should not be cooled and reheated a second time.

Critical Control Points (suggested only)

Receival temperature of PHF’s
Storage temperature of PHF’s
Cooking process- in cases where reduction of pathogens is required

For SSL and ESL cook-chill, if there is a cooking/ pasteurising step to reduce pathogen numbers, this would be a CCP. Sometimes cooking is for organoleptic reasons only. Refer comments on cold make-up products such as some cheesecakes.

Cooling of PHF’s
Transportation temperature of PHF’s

Validation (i.e. “will it work?”)

Validation is the act of finding or testing the truth of something e.g. what is the required lethality of the cooking process, and will the process achieve it? Validation ensures that the controls put in place will work.

Aspects of validation are-

The technical reference for the chosen critical limits (e.g. Food Standards Code, the “Blue Book”, etc)
Checking, for example, that a 6D cooking process is indeed being achieved, by measuring temperature and time at the slowest heating point
Challenge tests to validate shelf-life, using suitable reference organisms, especially if a process is chosen that differs from usual industry practice
Note- end of shelf-life micro testing, is not validation of a process
Validation is very important for high risk processes- is the chosen process going to deliver food safety?

Verification (i.e “did it work?”)

Verification activities for high risk products may include-

ATP swabbing of food contact surfaces and food production environment
Swabbing for environmental pathogens such as Listeria
Product micro testing for pathogens known to be associated with the food
End of shelf-life testing for pathogens known to be associated with the food

For further information please call 1300 730 134 or email info.aus@bsigroup.com.