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Hazard Analysis for Natural Flavors, Artificial Flavors and Nature-Ide


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#1 QAD_Rebisco

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Posted 26 May 2017 - 08:44 AM

Hi,

 

We are currently reviewing our hazard analysis for food additives and flavors. I would like to ask if hazard analysis for natural flavors also applies to artificial and nature-identical? Referring to Regulations Governing the Labelling of Prepackaged Food Products for definition of flavors (see attached), the artificial and nature-identical are just synthetic so we did not declare the milk hazards required by FDA for artificial milk, is this right? Thanks!

 

 

RBC Food Safety Audit

 


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#2 QAD_Rebisco

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Posted 26 May 2017 - 08:45 AM

Sorry, please see attached.

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#3 Ryan M.

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Posted 07 June 2017 - 12:16 AM

In my experience with flavors hazard analysis those would be separate.  In my previous experience we segregated natural from N&A, synthetic, and nature-identical because each subset comes with a unique set of hazards.  For one, with the synthetic you have potential hazards of toxic chemicals introduced in use as part of the synthetic flavor.  Natural flavors may have biological hazards that N&A, synthetic and nature-identical do not have.

 

However you chose, you have to justify it and completely flesh out the hazards.


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#4 Charles.C

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Posted 07 June 2017 - 04:18 AM

Hi,

 

We are currently reviewing our hazard analysis for food additives and flavors. I would like to ask if hazard analysis for natural flavors also applies to artificial and nature-identical? Referring to Regulations Governing the Labelling of Prepackaged Food Products for definition of flavors (see attached), the artificial and nature-identical are just synthetic so we did not declare the milk hazards required by FDA for artificial milk, is this right? Thanks!

 

 

RBC Food Safety Audit

 

Hi QAD,

 

It seems to me you are asking 2 different questions.

 

From an ingredient/Haz.Anal. POV, the basic requirement is IMO logically "food grade". This should have a definite local interpretation.

 

Regarding the "red" I suggest you re-read yr attachment. i do not comprehend yr last query. Sorry.


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Charles.C


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#5 QAD_Rebisco

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Posted 07 June 2017 - 10:06 AM

Hi Charles!

 

Below is the specific rules and regulations under complete list of ingredients:

  1. Natural Flavors - flavoring substance derived through appropriate physical processes from spices, herbs, fruits or fruit juices, vegetable or vegetable juices, edible yeast, bark, bud root, leaf of plant materials, meat, fish, poultry, eggs, dairy products or fermentation thereof.
  2. Nature-identical flavoring substances - substances chemically derived from aromatic materials or obtained synthetically, which are chemically identical to substances present in natural products intended for human consumption.
  3. Artificial flavoring substances - substances that impart flavor but which have not been identified in natural products or natural sources of flavorings.

 

Now, for milk powders, we have the following hazard analysis and justification:

 

1.       MILK POWDERS (Buttermilk Powder, Full Cream Milk Powder, Skimmed Milk Powder, Whey Powder)

 

1.1.     Biological - Salmonella, SPC/APC, Enterobacteriaceae: CAC/GL 21-1997 >Table 1. Milk and Dairy Products

 

1.2.     Chemical

 

1.2.1.   Antibiotics: CAC/RCP 57-2004 (Code of Hygienic Practice for Milk and Milk Products)

 

Antibiotics are used on many farms to treat mastitis infections. Cows under antibiotic treatment for mastitis infections may have antibiotic residues in their milk, therefore, milk from treated cows is either discarded or collected into a separate tank. Milk containing antibiotic residues is not used for human consumption. The legal standard, as defined by the FDA, requires that milk contain no detectable antibiotics when analyzed using approved test methods.

 

Many people are worried that there are antibiotics in their milk. It’s an important issue. If you continually take antibiotics, you can build immunity, and the antibiotic’s effectiveness goes down significantly. That’s why it is imperative that there cannot be antibiotics in our milk, so we can use antibiotics when we need them.

 

1.2.2.   Heavy Metals Lead: CODEX STAN 193-1995 (Codex General Standard for Contaminants and Toxins in Food and Feed) Adopted by the 33rd CCFAC (2001) > Maximum Level=0.02 mg/kg

 

Industrial and agricultural processes have resulted in an increased concentration of heavy metals in air, water, soil and subsequently, these metals are taken by plants or animals and find their ways into food chain. The presence of heavy metals in dairy products may be attributed to contamination of the original cow’s milk, which may be due to exposure of lactating cow to environmental pollution or consumption of feeding stuffs and water

 

1.2.3.   Allergen: CODEX STAN 1-1985 (General Standard for the Labelling of Prepackaged Foods) Section 4.2.1.4, Milk and milk products (lactose included).

 

1.2.4.   Aflatoxin M1: CODEX STAN 193-1995 (Codex General Standard for Contaminants and Toxins in Food and Feed) Adopted by the 33rd CCFAC (2001) > Maximum Level=0.5 mg/kg

 

Aflatoxins (AF) are a group of highly toxic secondary metabolic products of some Aspergillus spp.; they easily occur on feeds and foods during growth, harvest or storage. As AF are carcinogenic, teratogenic and mutagenic to animals and humans, contamination of feed and food is a current problem.

 

Milk has the greatest demonstrated potential for introducing AF residues from edible animal tissues into the human diet. Mammals who ingest aflatoxin B1 (AFB1)-contaminated diets eliminate into milk amounts of the principal 4-hydroxylated metabolite known as “milk toxin” or aflatoxin M1 (AFM1).

 

 

My concern is, is this applicable to Artificial Milk Flavor? If not, what else are the hazards for Artificial Milk Flavor and under what grounds? 

 

Thanks!

 

 

QAD RBC


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#6 Charles.C

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Posted 07 June 2017 - 10:24 AM

Hi Charles!

 

Below is the specific rules and regulations under complete list of ingredients:

  1. Natural Flavors - flavoring substance derived through appropriate physical processes from spices, herbs, fruits or fruit juices, vegetable or vegetable juices, edible yeast, bark, bud root, leaf of plant materials, meat, fish, poultry, eggs, dairy products or fermentation thereof.
  2. Nature-identical flavoring substances - substances chemically derived from aromatic materials or obtained synthetically, which are chemically identical to substances present in natural products intended for human consumption.
  3. Artificial flavoring substances - substances that impart flavor but which have not been identified in natural products or natural sources of flavorings.

 

Now, for milk powders, we have the following hazard analysis and justification:

 

1.       MILK POWDERS (Buttermilk Powder, Full Cream Milk Powder, Skimmed Milk Powder, Whey Powder)

 

1.1.     Biological - Salmonella, SPC/APC, Enterobacteriaceae: CAC/GL 21-1997 >Table 1. Milk and Dairy Products

 

1.2.     Chemical

 

1.2.1.   Antibiotics: CAC/RCP 57-2004 (Code of Hygienic Practice for Milk and Milk Products)

 

Antibiotics are used on many farms to treat mastitis infections. Cows under antibiotic treatment for mastitis infections may have antibiotic residues in their milk, therefore, milk from treated cows is either discarded or collected into a separate tank. Milk containing antibiotic residues is not used for human consumption. The legal standard, as defined by the FDA, requires that milk contain no detectable antibiotics when analyzed using approved test methods.

 

Many people are worried that there are antibiotics in their milk. It’s an important issue. If you continually take antibiotics, you can build immunity, and the antibiotic’s effectiveness goes down significantly. That’s why it is imperative that there cannot be antibiotics in our milk, so we can use antibiotics when we need them.

 

1.2.2.   Heavy Metals Lead: CODEX STAN 193-1995 (Codex General Standard for Contaminants and Toxins in Food and Feed) Adopted by the 33rd CCFAC (2001) > Maximum Level=0.02 mg/kg

 

Industrial and agricultural processes have resulted in an increased concentration of heavy metals in air, water, soil and subsequently, these metals are taken by plants or animals and find their ways into food chain. The presence of heavy metals in dairy products may be attributed to contamination of the original cow’s milk, which may be due to exposure of lactating cow to environmental pollution or consumption of feeding stuffs and water

 

1.2.3.   Allergen: CODEX STAN 1-1985 (General Standard for the Labelling of Prepackaged Foods) Section 4.2.1.4, Milk and milk products (lactose included).

 

1.2.4.   Aflatoxin M1: CODEX STAN 193-1995 (Codex General Standard for Contaminants and Toxins in Food and Feed) Adopted by the 33rd CCFAC (2001) > Maximum Level=0.5 mg/kg

 

Aflatoxins (AF) are a group of highly toxic secondary metabolic products of some Aspergillus spp.; they easily occur on feeds and foods during growth, harvest or storage. As AF are carcinogenic, teratogenic and mutagenic to animals and humans, contamination of feed and food is a current problem.

 

Milk has the greatest demonstrated potential for introducing AF residues from edible animal tissues into the human diet. Mammals who ingest aflatoxin B1 (AFB1)-contaminated diets eliminate into milk amounts of the principal 4-hydroxylated metabolite known as “milk toxin” or aflatoxin M1 (AFM1).

 

 

My concern is, is this applicable to Artificial Milk Flavor? If not, what else are the hazards for Artificial Milk Flavor and under what grounds? 

 

Thanks!

 

 

QAD RBC

 

Hi QAD,

 

The potential hazards presumably relate to the specific source / composition / intrinsic characteristics / applied process which generated the artificial milk flavour.

 

I don't quite see the relevance of the typical hazards for milk powder.


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Kind Regards,

 

Charles.C


#7 Charles.C

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Posted 07 June 2017 - 10:46 AM

addendum

 

I think yr initial requirement is to request a BPCA specification for the artificial milk flavour.


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Charles.C





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