Can controls for time/temperature abuse during processing or storage be included in a processors sanitation standard operating procedure rather than its HACCP plan?
No, to the extent that time/temperature abuse that can lead to the development of a hazard (e.g., histamine development or pathogen growth) is reasonably likely to occur at a step in the process, time/temperature abuse must be controlled through HACCP rather than through sanitation monitoring. Monitoring of time/temperature in a HACCP plan must be at a frequency to detect loss of control that would result in the development of a hazard.
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