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Argh! New inspector thinks HAACP is required to BBQ
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Harry Nutczak
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PostPosted: Mar 22 2013    Post subject: Argh! New inspector thinks HAACP is required to BBQ Reply with quote

A rant, venting, whatever you wanna call it/

We have a new inspector (isn't this fun!)
Who has BBQ confused with "Smoking as a method of food preservation"
And I am trying to do the dance with her without stepping on her toes too roughly ! (that's tough for me)

Has anyone else had overzealous inspectors they had to deal with?
( I know QFanatic has done the dance)
She is trying to tell me that I need a fullblown HAACP plan just to make our own bacon for use in the restaurant. I believe she is Confusing that with wholesale production, and shelf-stable modified atmosphere packaging requirements.

She expects me to submit a recipe for each specific style of bacon, and if there is a starting weight difference, (10 pounds compared to 15 pound belly) she says I need to treat that as a complete different recipe, and she also tells me these formulations need to be submitted to the food safety lab to be approved.

Can you believe this? I can't!!
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DrunkPlumber
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PostPosted: Mar 22 2013    Post subject: Reply with quote

"Just remember that the toes you may step on during your climb to the top will also be attached to the a$$es you'll be forced to kiss on your way back down!"



Just sayin'.
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RodinBangkok
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PostPosted: Mar 22 2013    Post subject: Reply with quote

Are you selling bacon by itself, if so it probably will fall under a category that is not fully cooked and not shelf stable. The packaging probably would not matter if your selling it as an item onto itself, it would still fall under that category.
If its only an ingredient and you can show its not being sold over the counter as a product or item onto itself, then I think you have a case to challenge.
I'm only basing what I know on knowledge of the federal standards, which I used when we set up our plans for retail and wholesale customers. For a Restaurant we have no requirements here, so my opinion just that!
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CrashLandingBBQ



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PostPosted: Mar 22 2013    Post subject: Reply with quote

Funny thing is my inspector showed up at, get this... 11:10 am Im standing there 10 min into my first lunch rush and she walks in. I had like 10 tickets and was in the weeds big time(first day open) but she was super cool and we got a 100!!! Hope your day gets better Harry.
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Harry Nutczak
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PostPosted: Mar 22 2013    Post subject: Reply with quote

Allegedly this misleading/confusing sentence she has been referring to has been in the Fed food code since 2005, My state adopted the fed code in its entirety decades ago.

I knew there was going to be some issues involved with our move to a larger location, But this kind of stuff I never imagined.

And, I just got off the phone with the state HD in the capitol for confirmation.

Yes, if you are adding cure to anything, you must write a friggin HAACP plan and apply for a variance from your health department to legally do so.
This has been federal law since 2005. If it gets heat treated or not.


Wow, what a kick in the nutsack this is. I am not feeling ambitious enough to sit here for hours on end doing a HAACP plan for each and every product that gets hit with some cure or maybe a little T+Q for a cheater-ring.

Edited to add;

Okay goobers, I found this page to help you get a HAACP plan together for your inspectors if you "Add a Curing agent to anything"

http://www.meathaccp.wisc.edu/Model_Haccp_Plans/index.html
good luck.................
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Geronimo
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PostPosted: Mar 22 2013    Post subject: Reply with quote

Some how the HD got wind (not hard in small towns) that you were making/selling bacon out of your restaurant.

When you applied for your HD permits, they (no doubt) asked you to "list" exactly what you would be cooking/selling there...did you list bacon??

If I remember right, you added bacon a quite a while after you had opened...

I wonder if you have to get prior approval to sell your "BBQ-Chicken Pizza done the right way! Real fresh-made Italian Sausage instead of the typical pre-cooked bits of dog kibble like the chain places use!" (your own words)

Probably more the "Fresh made Italian Sausage" than the pizza itself..or maybe both. Once they (HD) "have your number" they don't seem to back off.

And then there is your homemade jerky...

I know I and a issue (or two) with the HD (my catering business) because I was constantly changing my menu from my original submitted menu from when I first started.

They said I "must submit ANY changes for HD approval PRIOR to adding to menu"
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daddywoofdawg
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PostPosted: Mar 30 2013    Post subject: Reply with quote

why not have a local meat processor "make the bacon and sausage to your recipe,then smoke it yourself.then they have the haacp paperwork to do not you.
Here if it's not sold over the counter,and is fully cooked you don't have to do a haacp.
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Harry Nutczak
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PostPosted: Mar 30 2013    Post subject: Reply with quote

daddywoofdawg wrote:

Here if it's not sold over the counter,and is fully cooked you don't have to do a haacp.


You may want to double-check that, the way the federal food code has been revised is if "Anything gets a cure applied, you need to submit a HACCP plan" state and local authorities can be more stringent in regulations, but they cannot do less than federal laws.

As per Geronimo,
We are not required to submit our menu's for approval here, they simply use a point system to determine if you are; Simple, Moderate, or Complicated in regards to your onsite prep levels and your customer demographic..
I fit in the moderate because I do not serve a high-risk population (nursing home, immuno-compromised, etc) and we do not have drive-through service window.

A Drive-through or pick-up window adds points, and the licensing fee structure is derived from the level of points accrued.

A gas station convenience store or hot-dog stand is considered "Simple" because they are dealing with precooked and/or packaged RTE foods only.
99.99% of all restaurants are considered "Moderate" and I cannot think of a single restaurant location with the "Complicated" designation unless they are doing dry-aged, non heat treated fermented sausages in a drying room for months on end.
Wholesale meat processing houses are considered "Complicated" and also require an onsite state inspector to be there daily during production.
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daddywoofdawg
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PostPosted: Mar 31 2013    Post subject: Reply with quote

what would a steakhouse that dry ages there meat be?
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Harry Nutczak
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PostPosted: Mar 31 2013    Post subject: Reply with quote

daddywoofdawg wrote:
what would a steakhouse that dry ages there meat be?


Probably moderate or complicated, depending on what else they all do.
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chachahutbbq
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PostPosted: Apr 01 2013    Post subject: Reply with quote

Why not drop the cure & just go with a salt & sugar method. I would guess the major reason for the HACCP is the nitrates & potential to poison people if proportions are wrong.
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qfanatic01
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PostPosted: Apr 01 2013    Post subject: Reply with quote

Harry Nutczak wrote:
daddywoofdawg wrote:

Here if it's not sold over the counter,and is fully cooked you don't have to do a haacp.


You may want to double-check that, the way the federal food code has been revised is if "Anything gets a cure applied, you need to submit a HACCP plan" state and local authorities can be more stringent in regulations, but they cannot do less than federal laws.



According to the Minnesota state health department, currently running under 1995 federal codes, the federal codes are only recommendations and Minnesota has not adopted the current federal code. That was the crux of my outdoor smoker issue with the state. I complied with the amendments made to the federal code in 2002, but since the state had not adopted the code it did not apply. The MN state health dept has been writing their own code for the past 3 years. I have written my representatives in protest. We pay good tax dollars to the fed to take care of this and as Harry stated; the state and local authorities can then fine tune for any special needs or concerns. I'm soooooo tired of bureaucracy. Here's a large portion of our Government's budget problems.
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Geronimo
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PostPosted: Apr 01 2013    Post subject: Reply with quote

Thanks for the explanation Harry, some info I did not know!!
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Harry Nutczak
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PostPosted: Apr 01 2013    Post subject: Reply with quote

chachahutbbq wrote:
Why not drop the cure & just go with a salt & sugar method. I would guess the major reason for the HACCP is the nitrates & potential to poison people if proportions are wrong.


The nitrites are responsible for texture, and for keeping harmful bacterial growth to a minimum.
The temperatures used for during smoking bacon is right in the middle of the zone for optimum bacterial growth in a low oxygen environment, without a cure, it would be a bacterial mess and perfect for the proliferation of C. Botulinum.
Salt and sugar without nitrites wouldn't produce the product I want.

I am at page 27 right now in my product hazard analysis section of my HACCP plan right now.

There are about 9 or 10 other papers of various lengths that I still I need to do,
Such as:
Critical limit summary
Product description
Corrective action log
Scale calibrations log
Thermometer calibration logs
Time/Temp logs
SOP for products received
SOP for incoming products storage
SOP for finished product storage
Certifications from licensed supplier.

It seems like it goes on forever ever, and I still stand by me previous statement, "This is horsecrap!"
They should only require demonstration of knowledge and safety for a small-scale producer that does not wholesale or use modified atmosphere packaging..
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Harry Nutczak
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PostPosted: Apr 10 2013    Post subject: Reply with quote

Nope, still not done with all this.

Whats the hold up you ask? "Certifications from licensed suppliers" as I listed in a previous post.

I got it from my meat supplier instantly, my Sysco rep says that Sysco does not do anything like that. So my reply was "Then, by law I cannot purchase anything from you"
So I expect a call from his supervisor soon.

Butcher-Packer is getting me the required paperwork, I get my cure, spices, and casings from them.

Talking to someone at the state level I learned that the plan is to require HACCP plans for all products, if you cut your own steak, they will want a HACCP plan, if you make your own soups/stews, they want a HACCP plan!

They are trying to make it so every restaurant is forced to use nothing but frozen, pre-made heat and eat crap from some mega-supplier.

I have my state representative working with me to try and stop this from going forward, luckily he understands the ramifications because he is a restaurant owner himself.
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Geronimo
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PostPosted: Apr 10 2013    Post subject: Reply with quote

Harry Nutczak wrote:


Talking to someone at the state level I learned that the plan is to require HACCP plans for all products, if you cut your own steak, they will want a HACCP plan, if you make your own soups/stews, they want a HACCP plan!

They are trying to make it so every restaurant is forced to use nothing but frozen, pre-made heat and eat crap from some mega-supplier.

I have my state representative working with me to try and stop this from going forward, luckily he understands the ramifications because he is a restaurant owner himself.


Reading what I have in bold, does that mean a restaurant owner that makes their own BBQ sauce has to have a HACCP plan as well??? Shocked Shocked

Good luck with all of this and I know I don't have to say but...keep everyone posted as to your results
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Harry Nutczak
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PostPosted: Apr 10 2013    Post subject: Reply with quote

That is where they are trying to take it, so everything needs a formal HACCP plan.



Over-Regulation on steroids
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qfanatic01
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PostPosted: Apr 11 2013    Post subject: Reply with quote

I'd say they need to trim management and put more inspectors in the field if they want to do the public some real service. Not that I want to see an inspector more frequently. I've heard the chains are inspected monthly. That seems excessive unless it's their corporate doing it. They are looking to have every move documented. Kitchen staff will spend 10% or more of their time filling out logs instead of cooking and cleaning, so that the less than 1% of the time someone gets sick they can just pull the logs. The health dept will spend what % of their time reviewing plans and adding to their revenues for plan reviewing and annual HACCP fees. We are paying for way too much state and local management. We already have qualified folks at the federal level making policy. These folks at state level are just creating jobs for management or to justify their jobs. Here's more government waste. We need our state government to cut the fat not make more. Talk about BS. Folks need to let their representatives know they want better use of their tax dollars.
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Harry Nutczak
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PostPosted: Apr 11 2013    Post subject: Reply with quote

qfanatic01 wrote:
We need our state government to cut the fat not make more. Talk about BS. Folks need to let their representatives know they want better use of their tax dollars.


I agree fully, this is becoming an issue of bloated government agencies which are developing job security for themselves through over-regulation and doing little else.

Sadly they have us backed into a corner because they claim "It is for the safety of the people, it is a public health concern" And that statement makes it very difficult to fight because who could ever be against protecting the public health, right?

I was reading a study by Johns Hopkins Univ. a few years back regarding their own study on glove usage as opposed to "Bare Hand Contact" with RTE foods.
The study concluded that more problems are created by glove usage than what glove usage had hoped to fix.

One of the major ones was misuse and misunderstanding of the gloves. Many people look at gloves as being for their own personal protection as opposed to the protection of the consumers.
Their study found that the loss of tactile sensation through glove use had people handling raw products with the same gloves that they handle RTE's.

IE:
A cook grabs raw chicken to toss it in the grill, because he/she does not feel the chicken slime on their fingers, they do not think they need to remove the gloves, wash their hands, and apply new gloves as required.
With bare hands, you get a tactile clue that you need to wash your hands before handling anything else.

I have seen such gross misuse of gloves that I have forbid their usage in my kitchen! And with the full blessing of my inspector once he saw how we did things without them.
This guy actually stood off to the side of the line during a very busy rush and watched us feed well over 100 guests without bare hand contact with any RTE foods without gloves.
He stated he'd like to see them used anyways, so I put a pair on, and showed him what would happen.
Just by opening the cooler door to get product is a "Change of task" and would require me to shed those gloves, wash & dry my hands, and put on a new pair of gloves. I asked how many people would consider that a change of task, and then follow proper procedure be changing gloves. I had him inspect the handles on my cooler door to show that there is no build-up of mung on the handles, and asked what he sees at other places. He shook his head a little and explained that is typically one of his violations he writes. I asked how many times he sees handles grabbed with gloves on, yet them not being changed and then asked if I need to go on.

The one that really tweaks my beak is when I see someone at the register wearing gloves while handling money, then that same person goes onto preparing foods with those same damn gloves on. They have no clue.

Then the real gross incident which made me never go back to burger king ever again. I ordered a double whopper with bacon, as I place my order I see a lackey pushing a mop bucket through the back of the kitchen while wearing gloves, and I also hear the manager ask him if he is done cleaning the restrooms, Mr. Lackey replies that he just got done. Manager then says, "Good, you got an order up" So lackey walks to the line, and starts putting together my burger while wearing the same damn gloves he was wearing while cleaning the restrooms while wiping up urine, fecal matter, saliva, and who knows what else .

I get the attention of the manager to bring this to his attention, But he defended this gross misuse of gloves by saying "Our policy is to have employees change gloves every 30 minutes"
I again explained the sequence of events, and he simply repeated their "30 minute rule" without comprehending the problem. I got my refund even though he was not understanding my concerns. I even went over it again, and it still did not register with him.
I brought this up with my county health inspector the next time we spoke, and he told me about witnessing an employee using the restroom while wearing gloves, and returning to the food prep area with the same gloves on.

So next time you hear someone explain that; "Their employees wear food-handlers gloves for your protection" remember this incident.
And think about what you are doing when wearing gloves to make sure you and your employees are not making the same disgusting mistakes!

For you that think you cannot do your tasks without gloves, I'll share some of my most important tools on the line
1.) Table Scraper or dough knife
2.) tongs that are comfortable
3.) what I call "Turkey Forks" they are a large 4-prong fork designed to get under a turkey to lift it out of the roasting pan.

With those 3 simple and inexpensive tools, we are able to do most everything and not need gloves.
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corndog
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PostPosted: Apr 11 2013    Post subject: Reply with quote

Harry, thanks for the information and education...One of the biggest mistakes that I see, and that most get caught up with is complacency in the workplace...We all need to remain vigilant about food safety. We can try to adjust the gov't roll in this, but like you said, in the kitchen, we just need to remain vigilant and look out after our co-workers also...
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