Dr. Brian Nummer PhD


2020 Denver CFP Issues

  1. Special processes 3-502.11
    1. No mention of drying
    2. No mention of fermentation
    3. Question on canning foods in hermetically sealed containers (acid and low acid?)
  2. Fish ROP 48h rule.  Move to 3-502.11 that requires a variance (no HACCP?) so that RA can make sure safe process, or ?
  3. Did the option to remove ROP 30 d 34F to 7 day 41F get into code?
  4. ROP requirement for a manual 2X daily check of a frig with datalogger.

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