SEAPAC uses this shorter time allotment because it also includes a 30 minute block for the product in the coldest spot of the pouched tuna to reach 60°C. This timeframe is based upon heat penetration studies. Collectively, this approach ensures that the product is processed within 3 hours, which mirrors FDA’s recommendation. In fact, this approach is more conservative than FDA’s HACCP Guidance because the 3 hour time contemplates the time it takes for the product to reach 60°C.