Extended rising doughs with eggs & milk– reducing risks

Hi,

I am currently adapting my New Zealand “template food control plan” to my business in which I need to show that I am minimalising risk. I am trying to fit it into making Kolache dough with raw egg and pasteurised milk in the dough. There is general rules for holding, cooling and reheating prepared food that is potentially hazardous. There is a specialist bakery section that states that egg pulp must be pasteurised, and whole eggs must have the shell clean and free of cracks, there is also a statement about setting the use-by date for eggs, but there is no discussion about how long eggs or milk may sit in a bread dough at room temperature before cooking it. This may be because we are in a country where eggs a sold from the shelf and not from the fridge, and sitting for a few more hours at room temperature is not considered an issue, or it may be because rich sweet breads are quite rare here still. The general standard for prepared food in the danger zone is that it must be cooled within 2 hours, or thrown within 4 hours.

My “tried and true” recipe for Kolaches involves an initial rising at room temperature, an overnight delayed rising in the fridge (and sometimes freezing at this point), separating into balls, then a third rising, then the ball is indented, filled and baked. This has the dough go twice through the danger zone, and to remain in it for a total for more than 2 hours.

I am curious about what is the default “safe practice” where such egg/milk enriched sweet breads are more well-known. Would you use pasteurised egg pulp as a default? Is there any regulations as to how long you can have such dough rising?

I have looked at sourcing pasteurised egg pulp, but delivery of any egg pulp to our rural area is difficult, and sourcing organic or free-range egg pulp is pretty much impossible. I have considered trying to pasteurise my own, but I don’t have specialist temperature control equipment, and it seems a fine line between pasteurised and scrambled, and may make an even greater risk if I under-do it.

I am also wondering if I could do an initial pre-ferment or delayed rising in the fridge and then do 1-2 final risings outside a room temperature. I have never seen a recipe say to do the first rising in the fridge, but could this be done? (Maybe mix the melted butter with some flour and milk, and then add the remaining ingredients quite cold to quickly bring it to fridge temperature. )

Thanks for any help you may be able to give,