HACCP for flavourings / flavorings & fragrances

Hi All

I'm looking to develop a HACCP plan for a business dealing solely with flavourings and fragrances.
So far as i can see, there is no definitive use of any of the products produced, so they could appear in a food product or a non-food product (where HACCP wouldn't apply)
Has anyone else come across this, and has anyone managed to find a solution / develop appropriate procedures / policies

Any help most gratefully received

Now i have a little additional information:

The main import are essential oils of varying types, from a variety of countries.

the oils are tested by Gas Chromatograph to ensure that certain nasties aren't present. an arbitary 100ppm level has been set as acceptable for these various nasties (although this doesn't refer to any legal standard so far as i am able to ascertain)
oils may be filtered through a 1mm strainer for basic physical contaminant removal. some thinner oils may also be strained through muslin or filter paper. filtration is by gravity, not under pressure

some, very expensive, oils are not filtered at all (but these would still be tested)

Considering that we do not know what final product the essential oil would be an ingredient of or whether the oil would be used as a flavour or fragrance (the final product could vary from lemon tart to toilet cleaner to air freshener and include anything inbetween) it's a bit difficult to identify CCP's unless I consider initial testing as a CCP for whether it goes down the Flavour route, or Fragrance route (Fragrance if not compliant with the 100ppm level - or other statutory level)

so - i'm still looking for a little advice if there's anyone out there who has looked at something similar.

Any and all advice gratefully accepted

Dear Eurohygiene,

I would hv thought that yr first priority is to officially establish that the chemicals to which you are referring are legally allowed to be used as food ingredients, ie classified as food grade. I expect this involves contacting certain Government departments.
Fragrances not my area but I imagine some similar prohibitions exist so as to avoid encouraging people to nasally ingest dangerous chemicals.

Regarding "CCP". This terminology is typically invoked by a significant hazard within a raw material itself / its usage in a specific process. The former is considered above, the latter will depend on the process.

Rgds / Charles.C

Charles

we do know that the ingredients are allowed in foods (e.g. peppermint oil in chewing gum, orange oil as flavourings etc etc etc)

food legislation (and therefore info re ingredients) is much more robust than "scent" legislation, which may be covered by COSHH when in the workplace

i think that the difficulty i have is that we don't know how much of our ingredients are going into a particular food product, so if we have (for example) 100ppm of a specific contaminant in the oil, provided it is used at less than 1% concentration in the final food product, the (for example) permissable 1ppm specific contaminant would not be exceeded.

but as many manufacturers do not wish to release recipes it's rather tricky to identify what level of permissable contaminant any end food product would have within it

I'm unaware of permissable contamination levels in ingredients, only in end products

i feel as if i'm starting to open a can of worms.....

i should add that any ingredient we have, which is intended for food use has a FEMA number

if it doesn't have a FEMA number it isn't going anywhere near a food - so this has to be a CCP

Im in a similar business, but im developing my plan right now too. I actually just finished the course. But what about having a strict recieving program, with all neccesary regulations, msds, spec sheets etc... as far as a prerequisite to cover the raw material. IFRA documents can cover the application i believe... just a thought

I work in this area too; our CCPs are filtering and checking the containers (though that should really be taken care of by supplier assurance so it is really just filtering).

As far as I am aware and as stated by several auditors, analysis for dyes, ARs etc are all pre-requisites.

You may be surprised but HACCP is pretty common in the personal care ie fragrance / cosmetics / soap industry. It's obvious really, an error in any of these products could harm a consumer (blind them, cause a skin problem, burn them) and now they don't have the option to use animal testing as heavily as they did in years gone by.

So, don't just assume you're looking at food safety for HACCP and it might be worth contacting your fragrance customers for advice and guidance for HACCP for that purpose (it's not an area I'm particularly familiar with, I just know it exists) or getting some training in it.

As for the permissable levels of contaminants, can you not write your specifications in such a way as to make it acceptable; ie 'use at concentrations no greater than 1%'?

I don't know as well whether it would be practicable to have a 'food grade' product and a 'non food, non cosmetic grade' product (ie for toilet cleaner use. This could be for two reasons; you could market it as a selling point to new food customers, have slightly tighter tolerences (and charge a touch more) and any product which is contaminated in such a way as to prevent use in food could then be downgraded as long as it wouldn't cause a problem with loo cleaner either.

One thing I should point out though is you're heavily reliant on end product testing which is kind of 'anti-HACCP'. I know some industries can't get away from it totally but do you GC every batch? What 'nasties' are typically present? Why are they there? Can you prevent them contaminating in the first place? You get the idea...

GMO - I do have an issue with the fact that we are relying here on end-product testing.
contaminants are from source and may include nasties such as phthalates and a bundle of other stuff found in the environment coming from pollution being drawn into plants / trees and hence into their produce.

such pollution cannot be filtered out, obviously, and so the only way we feel it can be dealt with is to identify the level of contamination e.g. 100ppm (0.0001%) and considering the level at which flavours are ingredoents in foods identify for the customer that the level is below 100ppm.

Levels above 100ppm are considered for movement to a fragrance route, but always ensuring that levels of contaminants are below those legally acceptable in fragrances


Every single batch is assessed through the GC, at sample and receiving stage (to ensure the goods received are of the same standard as the sample recived)