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#1 chiagrower

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Posted 11 July 2014 - 07:36 PM

We are organic chia growers from Argentina and we were asked to supply big quantities of seeds to an important US chain of supermarkets in retail pouches. For this purpose, we will have to run kill steps and then pack it into retail pouches. Anybody knows what are the kill steps required by HACCP or the FDA?  

Thank you.


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#2 Caboose

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Posted 11 July 2014 - 08:02 PM

Chiagrower,

 

One of the first parts of a HACCP analysis is a risk assessment for your raw materials (raw seeds I'm assuming in this case) to see what kinds of contaminants (Biological, Chemical, and Physical) that are commonly associated with your product. Are the seeds regularly contaminated with E.Coli from fertilizers? Are they sprayed with a specific pesticide that could possibly remain on the seeds when they enter your factory (or that should be removed by an in-factory process)? Could bulk packaging contaminate the final product container? All of these need to be addressed in your HACCP analysis. A typical heat treatment would be 160 degF for 15 seconds, but would that have an undesirable effect on your final product?

 

I don't know if this is relevant but here are some FDA Best Practices for Retail Sprout Producers: http://www.fda.gov/F...n/ucm078758.htm

 

A bit more info on your process could help. Are you receiving raw seeds from a grower or growing them in your own fields? Would cooking hurt your end product? 

 

Here also is the FDA's Guidance for Industry: Guidance to minimize microbial food safety hazards for fresh fruits and vegetables: http://www.fda.gov/F...n/ucm064574.htm


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#3 Snookie

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Posted 11 July 2014 - 08:06 PM

What kill steps could be used may also be effected by end use.  Are these seeds going to be consumed raw, grown and then eaten or cooked before consumption?


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#4 chiagrower

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Posted 11 July 2014 - 09:35 PM

Our chia is organic and we are the growers so we don't use any fertilizer or pesticides. I still don't know how is the process for the kill step. I am trying to see if somebody knows and can tell me. I suppose it has to be done using some kind of radiation, or UV treatment. Rising the seeds temperature too much can change it a lot and we have to sell them raw which is the way consumers eat these seeds. I don't know if this is a standard procedure for just 15 secs.

I thought maybe HACCP had some standards for the kill step on each type of food...


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#5 SUSHIL

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Posted 12 July 2014 - 03:03 AM

Hello chiagrower,

       Your product should be free from physical hazards like metals pieces ,wood pieces and other harmful foreign objects etc, Chemical hazards (free from mould toxins like aflotoxin.ocratoxins etc,allergic substances ,heavy metals like lead,mercury ,arsenic etc),Microbiological hazards like salmonella,e-coli,bacillus cereus,clostridium perfringes,listeria monocytogenes etc .

           For this testing above parameters.you have to give your product to outside accreditated lab for analysis of your Chia seeds.

 

Attached below specifications and varoius nutritional and toxilogical information on Chia seeds--

and recent Recall information on sprouted chia seed powder contaminated with Salmonella

 

Chia Seed-Linked Salmonella Outbreak

 

 

Vist website-

http://www.foodsafet...gate-cooperate/

 

Attached Files


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#6 Snookie

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Posted 14 July 2014 - 04:55 PM

I thought maybe HACCP had some standards for the kill step on each type of food...

 

Not all products have a kill step. 


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#7 chiagrower

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Posted 14 July 2014 - 05:50 PM

Hello chiagrower,

       Your product should be free from physical hazards like metals pieces ,wood pieces and other harmful foreign objects etc, Chemical hazards (free from mould toxins like aflotoxin.ocratoxins etc,allergic substances ,heavy metals like lead,mercury ,arsenic etc),Microbiological hazards like salmonella,e-coli,bacillus cereus,clostridium perfringes,listeria monocytogenes etc .

           For this testing above parameters.you have to give your product to outside accreditated lab for analysis of your Chia seeds.

 

Attached below specifications and varoius nutritional and toxilogical information on Chia seeds--

and recent Recall information on sprouted chia seed powder contaminated with Salmonella

 

Chia Seed-Linked Salmonella Outbreak

 

 

Vist website-

http://www.foodsafet...gate-cooperate/

Thank you Sushil for all these pdf files. I read them all and I think it is all related to cleaning and sorting which could be summarized with this video: 

I still don't know what should be the kill step we must use for the chia seeds. On the FDA website you showed me, it talks about the chia sprouts and we are trying to produce edible chia seeds. The most specific thing I found on the FDA website says: "Seeds for sprouting should receive a treatment (such as 20,000 ppm calcium hypochlorite) that has been approved for reduction of pathogens in seeds or sprouts. " So, is this method of using calcium hypochlorite the one approved by FDA to make the seeds edible by any human being? I thought mybe it was by the use of radiation or UV treatment.

Do you or somebody know what kill step we should use?

Thank you.


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#8 chiagrower

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Posted 14 July 2014 - 05:54 PM

Not all products have a kill step. 

Maybe we should use ozone for the kill step? I wonder if it will still be considered organic?


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#9 Caboose

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Posted 14 July 2014 - 06:38 PM

Here is a FDA guidance for Fresh Produce with "no lethal kill step". http://www.fda.gov/F...m064458.htm#ch7

 

It looks like the focus of produce (which seems like what this chia seed product is most analogous to?) micro is prevention through GAP in the field and then GMPs in the factory. Agricultural commodities that are consumed raw are being reviewed now by the FDA in this proposed rule: http://www.fda.gov/F...A/ucm334114.htm

 

Best I can tell is that there is no kill step for RTE "fresh" produce (at least from the FDA)...you may need to explore a verification/validation sanitation approach. :uhm:


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#10 Charles.C

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Posted 14 July 2014 - 07:42 PM

Dear chiagrower,

 

The fact is that there is a significant  history of microbiological problems, eg Salmonella. being associated with this particular category of raw, fresh produce, seemingly due to its typical cultivation process.

 

 The FDA methodology described in Snookie’s link is a Best Practice based on the available data for the particular product(s), designed to minimally achieve a XLog reduction of  the specified target pathogens. As you probably realise, the treatment involves a massive concentration of applied hypochlorite.

 

As already suggested, you will logically need to acquire some related data on your  product, ie via risk assessment,  together with validation of  the effectiveness of any proposed treatment, eg via hypochlorite.

 

In case of a heating alternative, the typical European procedure is to risk assess the most "difficult-to-kill" pathogenic species likely to be present, often L.monocytogenes, and then devise a procedure accordingly. Other countries, eg USA, often implement a somewhat different logic. Once again, some data etc is necessary.

 

Rgds / Charles.C


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#11 Caboose

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Posted 14 July 2014 - 08:33 PM

Dear chiagrower,

 

The fact is that there is a significant  history of microbiological problems, eg Salmonella. being associated with this particular category of raw, fresh produce, seemingly due to its typical cultivation process.

 

 The FDA methodology described in Snookie’s link is a Best Practice based on the available data for the particular product(s), designed to minimally achieve a XLog reduction of  the specified target pathogens. As you probably realise, the treatment involves a massive concentration of applied hypochlorite.

 

 

chiagrower,

 

I think the hypochlorite treatment indicated in this document is for "seeds for sprouting" not seeds for consumption. This control is intended to reduce the incidence of contamination at the farm before the product enters the processing/packing facility. The next part of the document:

 

 

Sprout Production: Sprouters should implement appropriate practices to ensure that sprouts are not produced in violation of the act which prohibits the production of food under insanitary conditions which may render food injurious to health (21 U.S.C. 342(a)(4)). In addition to seed treatment and testing for pathogens (see below), sprouters should maintain facilities and equipment in a condition that will protect against contamination. Facilities with poor sanitation can significantly increase the risk of contaminating product. Sprouters should employ good sanitation practices as a standard operating procedure to maintain control throughout all stages of sprout production. Inadequate water quality and poor health and hygienic practices can all increase the risk of food becoming contaminated with pathogens. Sprouters may wish to review 21 CFR Part 110 which sets forth good manufacturing practices (GMPs) in manufacturing, packaging, or holding human food that cover these aspects of food production.

 

Followed by:

 

Testing for Pathogens: Because currently approved antimicrobials have not been shown to be capable of eliminating all pathogens from seed, sprout producers should conduct microbiological testing of spent irrigation water from each production lot to ensure that contaminated product is not distributed. Because testing for pathogens can be done with irrigation water as early as 48 hours into what is generally a 3 to 10 day growing period, producers who plan accordingly can obtain test results before shipping product without losing product shelf-life. Testing, whether done by the producer or contracted out, should be done by trained personnel, in a qualified laboratory, using validated methods. Additional information on sample collection and microbial testing, including how to sample and test sprouts when testing spent irrigation water is not practicable (as may be the case with soil-grown sprouts), can be found in a companion guidance document referenced below.

 

This FDA document is focused on seeds at the farm, not for consumption, although since you are the producer and the seller you could apply these controls.


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#12 chiagrower

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Posted 14 July 2014 - 09:03 PM

I read all of FDA's articles but they all talk about how good our sanitation practices must be, but they are not specific on saying which one I should use for my seeds. So, it looks like the FDA doesn't mandate any specific procedure. Then it should be something we choose from industry standards, right?

So, what kill step should we use?

Ozone?

Calcium hypochlorite?

Radiation?

UV treatment?

 

Thank you.


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#13 chiagrower

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Posted 14 July 2014 - 09:14 PM

Maybe using Ionized irradiation, x-rays, gamma-rays, or e-beam?

http://www.fda.gov/F...ing/default.htm


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#14 Charles.C

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Posted 15 July 2014 - 01:44 AM

Dear Caboose,

 

You’re correct. The hypochlorite treatment was/is focused on seed > sprout processors. The draconian nature of the procedure reflects the well-documented potential for rapid amplification of any “low” levels of Salmonella in the raw material (or subsequently acquired) during the germination process, eg -

http://www.theguardi...-e-coli-germany

 

A little background is maybe useful as noted post #5 . I deduce the thread is related to current items like this –

 

http://munchies.vice...-seed-outbreak/

http://www.fda.gov/F...s/ucm399235.htm

 

All the incriminated product (so far) reported seems to be the sprouted powder although the seed (origin X) is obviously a possible source (plus the process of course) eg –

 

Chia powder is made by sprouting the seeds and then grinding up the sprouts. Since sprouts are a common vehicle for pathogens, Gieraltowski said this process may be amplifying the contamination of the seeds.

http://www.foodsafet...l/#.U8RxfHLVBkg

 

So I guess any buyer’s immediate necessity is focussed on how to ensure seed material is Salmonella free.

And as you originally commented, this goes back to the (seed) process. I assume the latter  is everywhere similar to that shown in Sushil’s attachment, ie without a bacterial “elimination” step.

 

The document (1999) quoted in post #11 contains another  general comment  –

 

Contamination of seeds appears to be sporadic and usually at low levels.

 

 I don’t know if this is still a representative global comment.? Hopefully not. I think I noticed a comment in one recent publication that this (May-June 2014) incident is the first reported pathogen problem related to “Chia seeds”.

 

I daresay further data on the raw materials / processes in current outbreak will appear in due course although news now seems to have gone rather quiet ?

 

To return to the OP, possible control methods will, as noted, depend on a risk assessment/DATA. I would imagine that all the methods mentioned in previous post (seemingly heat is now excluded) are theoretically usable but whether acceptable to RTE product/customer/destination/cost no idea. Radiation would perhaps demand more validation than the others from a USA POV ?

 

Rgds / Charles.C

 

PS - i also noticed this UK comment via parallel forum news thread -

 

http://www.food.gov....ia#.U8Qjq3LVBkg

 

PPS - I should have noted that as implied in Caboose's previous post, if you are certain that yr product is for direct consumption and "free" of significant micro.pathogens like salmonella it is probably (not my product area of expertise) not necessary to use elevated hypochlorite levels as for sprouts procedure. Routine raw vegetable / fruit lines for RTE products use levels nearer max. 100 ppm AFAIK albeit the likely reduction of any pathogens present is maybe max 2D rather than 5-6


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#15 SUSHIL

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Posted 15 July 2014 - 05:12 AM

Hello Chiagrower,

        If you are a grower it is best to follow GAP at farm levels and GHP,GMP at industry levels.Generally seeds of any type have moisture levels below 8% and will not support microbial growth. Only highly abused seeds at farm levels and industrial levels will be contaminated with pathogens.

 Therefore first give your raw produce with proper sampling procedure (sample size say 1,2 or 10 tonnes) to outside accreditated lab for pathogen testing and then to see whether to reject the product  or not.

Normally treatment to remove pathoigens from raw produce is very harsh and may deteriorate the quality of the product/seeds.

for e.g.say steaming/heat drying of seeds until  seed reach an internal temp of 75 degree centigrade .

or traetment of seeds with sodiun hypochlorite with 100-200 ppm chlorine and then with fresh water treatment to remove chlorine and then again drying of seeds to remove moisture (moisture below 8%).

All these treatments will affect the quality of the produce.

U.V. traetment is used for Water /Environmental air  and it rays cannot penetrate seeds .However it can be used as GMP in plant.


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#16 chiagrower

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Posted 15 July 2014 - 06:33 PM

Dear Caboose,

 

You’re correct. The hypochlorite treatment was/is focused on seed > sprout processors. The draconian nature of the procedure reflects the well-documented potential for rapid amplification of any “low” levels of Salmonella in the raw material (or subsequently acquired) during the germination process, eg -

http://www.theguardi...-e-coli-germany

 

A little background is maybe useful as noted post #5 . I deduce the thread is related to current items like this –

 

http://munchies.vice...-seed-outbreak/

http://www.fda.gov/F...s/ucm399235.htm

 

All the incriminated product (so far) reported seems to be the sprouted powder although the seed (origin X) is obviously a possible source (plus the process of course) eg –

 

http://www.foodsafet...l/#.U8RxfHLVBkg

 

So I guess any buyer’s immediate necessity is focussed on how to ensure seed material is Salmonella free.

And as you originally commented, this goes back to the (seed) process. I assume the latter  is everywhere similar to that shown in Sushil’s attachment, ie without a bacterial “elimination” step.

 

The document (1999) quoted in post #11 contains another  general comment  –

 

 

 I don’t know if this is still a representative global comment.? Hopefully not. I think I noticed a comment in one recent publication that this (May-June 2014) incident is the first reported pathogen problem related to “Chia seeds”.

 

I daresay further data on the raw materials / processes in current outbreak will appear in due course although news now seems to have gone rather quiet ?

 

To return to the OP, possible control methods will, as noted, depend on a risk assessment/DATA. I would imagine that all the methods mentioned in previous post (seemingly heat is now excluded) are theoretically usable but whether acceptable to RTE product/customer/destination/cost no idea. Radiation would perhaps demand more validation than the others from a USA POV ?

 

Rgds / Charles.C

 

PS - i also noticed this UK comment via parallel forum news thread -

 

http://www.food.gov....ia#.U8Qjq3LVBkg

 

PPS - I should have noted that as implied in Caboose's previous post, if you are certain that yr product is for direct consumption and "free" of significant micro.pathogens like salmonella it is probably (not my product area of expertise) not necessary to use elevated hypochlorite levels as for sprouts procedure. Routine raw vegetable / fruit lines for RTE products use levels nearer max. 100 ppm AFAIK albeit the likely reduction of any pathogens present is maybe max 2D rather than 5-6

 

We are not producing chia sprouts, we are just producing chia seeds, so all these articles don't apply I think... It seems that the difference is in the percentage of moisture. Sprouts are dangerous whereas just dry seeds, don`t attract pathogens apparently...


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#17 chiagrower

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Posted 15 July 2014 - 06:39 PM

Hello Chiagrower,

        If you are a grower it is best to follow GAP at farm levels and GHP,GMP at industry levels.Generally seeds of any type have moisture levels below 8% and will not support microbial growth. Only highly abused seeds at farm levels and industrial levels will be contaminated with pathogens.

 Therefore first give your raw produce with proper sampling procedure (sample size say 1,2 or 10 tonnes) to outside accreditated lab for pathogen testing and then to see whether to reject the product  or not.

Normally treatment to remove pathoigens from raw produce is very harsh and may deteriorate the quality of the product/seeds.

for e.g.say steaming/heat drying of seeds until  seed reach an internal temp of 75 degree centigrade .

or traetment of seeds with sodiun hypochlorite with 100-200 ppm chlorine and then with fresh water treatment to remove chlorine and then again drying of seeds to remove moisture (moisture below 8%).

All these treatments will affect the quality of the produce.

U.V. traetment is used for Water /Environmental air  and it rays cannot penetrate seeds .However it can be used as GMP in plant.

 

So, you mean that if the seeds have less than 8% of moisture, then there is no need of any kill step at all? You mean that with just simply testing (GMP method maybe) some samples and not finding any pathogen then the FDA will consider that all seeds are clean and without any bacteria and ready for human consumption. So, it is just a probability thing?

Since we are producing organic chia seeds, maybe if we use irradiation or UV treatment, it won't be organic anymore?


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#18 Caboose

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Posted 15 July 2014 - 07:43 PM

So, you mean that if the seeds have less than 8% of moisture, then there is no need of any kill step at all? You mean that with just simply testing (GMP method maybe) some samples and not finding any pathogen then the FDA will consider that all seeds are clean and without any bacteria and ready for human consumption. So, it is just a probability thing?

Since we are producing organic chia seeds, maybe if we use irradiation or UV treatment, it won't be organic anymore?

 

The idea is that bacteria need a certain water activity to grow so if your product is dry they will not be able to. If no water is added to the seeds during the processing you perform on them (bagging/sorting?) then they could be considered to be relatively safe provided that: The plants they were grown from were not contaminated (testing of the water used for the chia growing for Salmonella / E. coli), your machinery was not contaminated (taking swabs from your equipment, like from hopper joints or crevices in zone one [direct product contact]), and your packaging materials were not contaminated (CoA from the packaging supplier or swabbing some packing materials). You would then need to analyze those swabs in a lab for the target bacteria. If none show up then you know that run of product is safe. I package dry powder products and we have no kill step, since heat or chemicals are not possible to use (sugar + heat = gooey sadness :( ) and rely on the quality of our raw/packaging materials and SSOPs to prevent microbial contamination.

 

This slide show illustrates the same issues: http://www.foodprote...11Ede/Betts.pdf

 

The focus on low Aw foods is receiving uncontaminated raw materials. If you perform testing on your raw materials and your end processing equipment you should be able to show that your product is safe for consumption as a RTE.

 

Here is another reference from the University of California: http://ucanr.edu/sit...and_Sanitizers/

 

They use 200ppm Chlorine for actual produce sanitation (and also list the 20,000ppm used for seeds for sprouting) but I imagine this procedure would then need a water rinse afterwards because 200ppm chlorine needs a rinse for food contact surface sanitation. This article also talks about the difficulties/shortfalls of sanitizing fresh produce.

 

Finally this article: http://www.foodsafet...e/#.U8WDAPldXas

 

It talks about UV treatment using a tumbler to expose large amounts of fresh produce to UV rays that could kill your target bacteria (E. coli / Salmonella). You may want to explore this UV option further. Irradiation treatments is probably not a good bet because of people wielding pitchforks. There isn't enough evidence to prove that irradiation treatments aren't dangerous (even though there is evidence that says they are not dangerous :yeahrite: ) so they are definitely dangerous. They could also have a negative effect on your product like melting it (maybe  :death: ).

 

Hope something here helps!


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#19 chiagrower

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Posted 15 July 2014 - 09:16 PM

The idea is that bacteria need a certain water activity to grow so if your product is dry they will not be able to. If no water is added to the seeds during the processing you perform on them (bagging/sorting?) then they could be considered to be relatively safe provided that: The plants they were grown from were not contaminated (testing of the water used for the chia growing for Salmonella / E. coli), your machinery was not contaminated (taking swabs from your equipment, like from hopper joints or crevices in zone one [direct product contact]), and your packaging materials were not contaminated (CoA from the packaging supplier or swabbing some packing materials). You would then need to analyze those swabs in a lab for the target bacteria. If none show up then you know that run of product is safe. I package dry powder products and we have no kill step, since heat or chemicals are not possible to use (sugar + heat = gooey sadness :( ) and rely on the quality of our raw/packaging materials and SSOPs to prevent microbial contamination.

 

This slide show illustrates the same issues: http://www.foodprote...11Ede/Betts.pdf

 

The focus on low Aw foods is receiving uncontaminated raw materials. If you perform testing on your raw materials and your end processing equipment you should be able to show that your product is safe for consumption as a RTE.

 

Here is another reference from the University of California: http://ucanr.edu/sit...and_Sanitizers/

 

They use 200ppm Chlorine for actual produce sanitation (and also list the 20,000ppm used for seeds for sprouting) but I imagine this procedure would then need a water rinse afterwards because 200ppm chlorine needs a rinse for food contact surface sanitation. This article also talks about the difficulties/shortfalls of sanitizing fresh produce.

 

Finally this article: http://www.foodsafet...e/#.U8WDAPldXas

 

It talks about UV treatment using a tumbler to expose large amounts of fresh produce to UV rays that could kill your target bacteria (E. coli / Salmonella). You may want to explore this UV option further. Irradiation treatments is probably not a good bet because of people wielding pitchforks. There isn't enough evidence to prove that irradiation treatments aren't dangerous (even though there is evidence that says they are not dangerous :yeahrite: ) so they are definitely dangerous. They could also have a negative effect on your product like melting it (maybe  :death: ).

 

Hope something here helps!

 

Well, it looks that for being "organic" then you shouldn't be irradiating any food. It seems the FDA wants us to irradiate them anyways but then it won't be organic anymore.

So, if we keep our harvest-cleaning-sorting process with a moisture level of under 8%, then no bacteria will be present in our seeds? But we are relying in probabilities here... What if one pathogen gets in one of our process? So, no kill step at all?

Actually, our US client asked us what kill step we were planning on performing on the seeds and he knows this is organic food. So he presumes that some kill step has to happen in the process.

I mean, just for being able to label our product as 'organic' we are going to get into all the risk of pretending that no bacteria gets into our seeds at all? Just because moisture is under 8%? Dirt, for example, is extracted in a mechanical way, so this means, that you never remove 100% of dirt. probably 99.9999%. Well, yes, if there is no moisture present, then it will be clean dirt...


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#20 Charles.C

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Posted 16 July 2014 - 04:44 AM

Dear chiagrower,

 

So, if we keep our harvest-cleaning-sorting process with a moisture level of under 8%, then no bacteria will be present in our seeds?

 

I think you are maybe confusing Contamination and Growth.

 

Actually, our US client asked us what kill step we were planning on performing on the seeds and he knows this is organic food. So he presumes that some kill step has to happen in the process.

 

See my previous post ? I think this is known as a knee-jerk reaction.

 

Some of yr queries essentally relate to the agreed specification of yr product. For example, buyers normally expect Salmonella to be absent from RTE food, regardless of whether organic or not. Some of the previous posts have explained how you can provide assurance that this criterion is fulfilled. "kill step" loosely suggests microbial reductions of the order of 6D.

 

This FDA link is, i think, a sort of "update" to the link in post#9 and details various available microbial reduction procedures for fresh produce. Seeds are specifically mentioned here and there. As you know, many (most?) of the procedures are unavailable for "organic" labelling.

http://www.fda.gov/F...s/ucm091363.htm

 

This short but quite informative publication due Campden also has some organic commments.

Attached File  Fresh produce, microbial,, Campden.pdf   228.06KB   33 downloads

 

Various Google Books have detailed discussions of the "limited" organic possibilities also. And the potential consequences +/-, eg Global Safety of Fresh Produce/Hoorfar

 

Rgds / Charles.C


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#21 chiagrower

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Posted 16 July 2014 - 09:07 PM

Dear chiagrower,

 

I think you are maybe confusing Contamination and Growth.

 

See my previous post ? I think this is known as a knee-jerk reaction.

 

Some of yr queries essentally relate to the agreed specification of yr product. For example, buyers normally expect Salmonella to be absent from RTE food, regardless of whether organic or not. Some of the previous posts have explained how you can provide assurance that this criterion is fulfilled. "kill step" loosely suggests microbial reductions of the order of 6D.

 

This FDA link is, i think, a sort of "update" to the link in post#9 and details various available microbial reduction procedures for fresh produce. Seeds are specifically mentioned here and there. As you know, many (most?) of the procedures are unavailable for "organic" labelling.

http://www.fda.gov/F...s/ucm091363.htm

 

This short but quite informative publication due Campden also has some organic commments.

attachicon.gifFresh produce, microbial,, Campden.pdf

 

Various Google Books have detailed discussions of the "limited" organic possibilities also. And the potential consequences +/-, eg Global Safety of Fresh Produce/Hoorfar

 

Rgds / Charles.C

 

Thank you Charles.

Well, I made some more research on all this matter today and I found out that supposedly, these chia seeds or any other seeds, are ok to just pack them with just a cleaning and sorting process but without any kill step if the moisture level is under 8% and performing lab tests right before packing in the case you are selling them in places not too far away to where your Processing plant is. But, if you will export these retail pouches with seeds inside in containers by ship and if this ship has to cross the Equator and be exposed to very high temperatures, then maybe we need a kill step like the gamma rays irradiation. I talked to people in Argentina that offer this service and they think that a range of 8 to 15 kilograys is sufficient to kill all possible bacteria.

The other option could be to ship it in refrigerated containers without doing any irradiation?


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#22 Charles.C

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Posted 17 July 2014 - 05:53 AM

Dear chiagrower,

 

AFAIK, a moisture level of 7.9% in no way guarantees that the raw material is free of pathogens like Salmonella. If you believe it does, i would be interested in seeing the validation.

 

If the raw material is contaminated, so will be the environment that you work in and consequently other "clean" incoming materials. This is known as cross-contamination.

 

Routine lab tests for Salmonella based on 1 or 2  samples may detect gross contamination but low levels will probably give negative results. IMEX (not seeds) the USA-FDA typically lake much larger samples at import than any other country and use state-of-the-art detection equipment.

 

Nonetheless, as shown in the posts from Sushil, simple packing processes do exist. Their use depends on how much risk the exporter is willing to take with respect to the supplier / raw material / environment, their reputation(?). Ideally the risk is based on validated knowledge / data / science, ie risk assessment.

 

Options like radiation will presumably depend on any relevant legislatory / customer agreement.

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


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#23 chiagrower

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Posted 29 July 2014 - 03:49 PM

If we are going to send our chia seeds to the US, do we need to do some paperwork for the FDA or another US customs institution in order to get our containers into the country and not be rejected at the US port? Is there any usual procedure for this?

Thank you


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#24 GSH19

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Posted 29 July 2014 - 08:13 PM

Dear Chia grower,

Heat treatment works well for most herbs, spices, seeds in our facility.


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#25 SQF1188

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Posted 30 July 2014 - 06:14 PM

If we are going to send our chia seeds to the US, do we need to do some paperwork for the FDA or another US customs institution in order to get our containers into the country and not be rejected at the US port? Is there any usual procedure for this?

Thank you

Any imported product would need to meet FDA regulatory requirements. This is a job in itself to know if you meet all regulations. There is a process for any imported food products coming into the US but I'm not sure what it entails. Might be best to look for some legal help on that.


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