6 replies to this topic

[Gareth Houston]

Hi All

 

 

I am looking for some advice regarding manufacturing and bottling unpasteurized fruit and vegetable juices in the UK. (Note I don't want to use HPP treatment either)

 

The process will rely on a controlled washing procedure to remove/reduce any harmful pathogens on the fruit/vegetables to a safe level. (I will use the guidance issued in the Food Standards Agencies E.coli Guidance, which I will use as part of my validation for the CCP) Following the washing step I will adhere to strict hygienic handling/processing procedures (GMP/GHP) to ensure the product doesn't become contaminated up until bottling. (Bottle will be sterile and this will be covered in my food safety management system)  

 

As the controlled washing procedure is my only CCP, what would my critical limit be and how would I measure it?  I assume it would be consistent adherence to the validated controlled washing procedure. I would also assume that visual monitoring of the controlled washing procedure would be sufficient to determine acceptability from unacceptability.  Is this Correct?

 

As the business will be small, I don't envisage undertaking micro tests as specified under EC Reg 2073 as part of my verification check and I will want to rely solely on my robust HACCP procedures and regular internal audits of these procedures (bearing in mind that most procedures will fall under GMP/GHP).  Would this be adequate?

 

Bearing in mind that certain strains of E.coli 0157 have low infective doses, would a controlled washing procedure as specified by the Food Standards Agency be sufficient as a CCP i.e. Washing will help to remove bacteria including E. coli from the surface of fruit and vegetables. Most of the bacteria will be in the soil attached to the produce. Washing to remove any soil is, therefore, particularly important. When washing vegetables, do not just hold them under the running tap, rub them under water, for example in a bowl of fresh water starting with the least soiled items first and then give each of them a final rinse. Washing loose produce is particularly important as it tends to have more soil attached to it than pre-packaged fruit and vegetables – NHS choices - How to wash fruits and vegetables: http://www.nhs.uk/Li...getables.aspx''

 

Would you consider this advice from the Food Standards Agency as validation for my CCP?

 

 

Any Feedback you can provide would be fantastic

 

 

 

 

 

 

[Gareth Houston]

Please also note 

 

The product will be a chilled product with storage instructions on the label I.e keep refrigerated

 

The shelf life for the product will also be short (2-3 days) Still waiting shelf life test results

 

The product will not have any preservatives including natural preservatives such as citric acid

[Charles.C]

Hi Gareth Houston,

 

Thanks for yr query and Welcome to the Forum !

 

IMO you are considering to enter an area of food production which I would describe as “sensitive”.

 

The specific fruits/processing steps envisaged are not totally detailed so I have attached some model (fruit) examples at the end.

 

I am not familiar with UK regulations for this product category but, just as an example, here is a USA comment  –

 

Retail establishments or businesses that make and sell juice directly to consumers and do not sell or distribute juice to other businesses are exempt from the juice HACCP regulation, but must comply with FDA's food labeling regulation in 21 CFR 101.17(g) that requires a warning statement on packaged fruit and vegetable juice products that have not been processed to prevent, reduce, or eliminate pathogenic microorganisms that may be present, and with any applicable state regulations.

http://www.fda.gov/F...e/ucm072557.htm

 

I have attached a few haccp related documents which relate to most of the queries in yr OP.  Unfortunately none are particularly recent. One is from the UK (unp3, 2006) so that the micro. criteria used for acceptability may now have changed somewhat. Current values have been posted on this forum as listed by HPA.

 

Based on unp3 below I anticipate the product would (minimally) need to comply with appropriate UK micro. regs for an RTE food.
 

The process will rely on a controlled washing procedure to remove/reduce any harmful pathogens on the fruit/vegetables to a safe level. (I will use the guidance issued in the Food Standards Agencies E.coli Guidance, which I will use as part of my validation for the CCP) Following the washing step I will adhere to strict hygienic handling/processing procedures (GMP/GHP) to ensure the product doesn't become contaminated up until bottling. (Bottle will be sterile and this will be covered in my food safety management system)

(1a) As the controlled washing procedure is my only CCP, what would my critical limit be and how would I measure it?

Some possibilities are given in unp1, unp2, unp3 for orange juice, etc. Some FS Standards might regard the washing step as a PRP or OPRP.

 

(1b) I assume it would be consistent adherence to the validated controlled washing procedure. I would also assume that visual monitoring of the controlled washing procedure would be sufficient to determine acceptability from unacceptability.

Is this Correct?

 

Not entirely.

From unp1 – “Establishing CLs based on inspections or visual observations is more difficult. It involves setting an  accept/reject decision based on subjective evaluation.

Examples: a food product contact surface is not clean; washed fruit is not clean; or acceptance/rejection of raw materials based upon sensory evaluation.”

Such a qualitative critical limit must still be validatable/verifiable as capable of yielding a finished product compliant to any required micro. levels.

Some authorities will only accept numerically specific critical limits.

 

(2) As the business will be small, I don't envisage undertaking micro tests as specified under EC Reg 2073 as part of my verification check and I will want to rely solely on my robust HACCP procedures and regular internal audits of these procedures (bearing in mind that most procedures will fall under MP/GHP).  Would this be adequate?

Not if you wish to ensure product compliance with local micro. regs so as to avoid potential safety incidents/recalls. And possibly as required by the local regs. themselves (?)

 

 

(3) Bearing in mind that certain strains of E.coli 0157 have low infective doses, would a controlled washing procedure as specified by the Food Standards Agency be sufficient as a CCP i.e. Washing will help to remove bacteria including E. coli from the surface of fruit and vegetables. Most of the bacteria will be in the soil attached to the produce. Washing to remove any soil is, therefore, particularly important. When washing vegetables, do not just hold them under the running tap, rub them under water, for example in a bowl of fresh water starting with the least soiled items first and then give each of them a final rinse. Washing loose produce is particularly important as it tends to have more soil attached to it than pre-packaged fruit and vegetables – NHS choices - How to wash fruits and vegetables: http://www.nhs.uk/Li...getables.aspx''

Please supply an appropriate FSA, HACCP  link.

 

(4) Would you consider this advice from the Food Standards Agency as validation for my CCP?

(See [3])

 unp1 - FS07500-1.pdf   140.06KB   107 downloads

 unp2 - HACCP model fresh squeezed orange juice (undated).pdf   20KB   109 downloads

 unp3 - lacors (2002).doc   465KB   93 downloads

[SUSHIL]

Hello Gareth Houston,

               There is no guarantee that cleaning steps will remove pathogens fron the products without pasteurisation of the acidic juices (with Ph below 4.5).Also there is a danger of Clostridium botulinum

bacteria growing in juices with Ph above 4.5 and which can pose a risk of botulism poisoning.

 

 

Please visit the FDA website http://www.fda.gov/F...e/ucm072481.htm

Guidance for Industry: Refrigerated Carrot Juice and Other Refrigerated Low-Acid Juices

[Charles.C]

 

Hello Gareth Houston,

               There is no guarantee that cleaning steps will remove pathogens fron the products without pasteurisation of the acidic juices (with Ph below 4.5).Also there is a danger of Clostridium botulinum

bacteria growing in juices with Ph above 4.5 and which can pose a risk of botulism poisoning.

 

 

Please visit the FDA website http://www.fda.gov/F...e/ucm072481.htm

Guidance for Industry: Refrigerated Carrot Juice and Other Refrigerated Low-Acid Juices

 

 

Well-stated, pH is everything. (Plus moisture, ++)

 

C.botulinum typically more significant in vegetables than fruits due intrinsic pH values.

 

Here are a few more related attachments including an additional, quite detailed, haccp plan.

 

 unp4 - Microbiological risk for unpasteurised fruit juices.pdf   1.61MB   94 downloads

 unp5 - HACCP_Plan_Orange_Juice (unpasteurised).pdf   331.64KB   80 downloads

 IFST review - factors that influence microbia growth.pdf   255.51KB   70 downloads

 

I also noticed this quite useful table (with comments) listing  “popular”  microbial pathogenic species for a wide range of food categories. The list will never be 100% complete of course.

 

 Food types and their microorganisms of FS concern.pdf   405.88KB   85 downloads

[Satya Vavilapalli]

Dear Gareth Houston,

 

Welcome to the forum.

 

IMO controlled washing procedure can't be a CCP and you can take care about the micro levels in the finished product.

can be a OPRP.

 

Regards

Satya

[ahmedmourad]

Dear Gareth:

 

you can use Any Approved chemical in the Washing Process,\

 

Chlorine , Per acetic acid or others

 

Critical Limits for this CCP biological will be the Concentration of the Chemical and the time of washing as Example

these limits will be determined after Doing validation test Microbiologically, Followed by shelf life test.

 

 

 

BW

ahmedmourad