How to validate a hazard analysis BEFORE the auditor comes, re-coffee

I am the "documentation" person for a coffee roaster/packager. In response to FSMA, the process flow chart for the facility is now much more detailed. A new hazard analysis has been done based on the new process flow chart. Two critical control points have been identified.

Here's the thing. Online research points to there being no critical pontrol points for coffee roasting/packaging. I can't find anything to compare with.

Any suggestions?

What CCP's have you identified?

Mike

I am the "documentation" person for a coffee roaster/packager. In response to FSMA, the process flow chart for the facility is now much more detailed. A new hazard analysis has been done based on the new process flow chart. Two critical control points have been identified.

 

Here's the thing. Online research points to there being no critical pontrol points for coffee roasting/packaging. I can't find anything to compare with.

 

Any suggestions?

Dear bzuelch,

It depends on yr particular process and yr particular haccp methodology (eg Codex, ISO22000). And FSMA of course.

Not my area but I have seen CCPs suggested for drying (moisure/mould/OTA control), raw material (OTA control), roasting step (salmonella control), metal detector (metal control) and a few, more atypical, others.

A few of the related texts to above are attached below –

cf1 - Coffee - FSMA (2013).pdf   1.3MB   989 downloads

cf2 - Coffee - mycotoxins (OTA).pdf   170.69KB   800 downloads

cf3 - coffee, haccp critical limits, FAO.ppt   273KB   992 downloads

Additionally to previous post, I suggest you post yr process / haccp links already utilised.

Rgds / Charles.C

PS - there is at least one, maybe interesting to you, coffee thread on the forum, here -

http://www.ifsqn.com...ltiple-screens/

PPS - yr topic title is slightly tangential to OP. May not be picked up by coffee lovers. :smile:

Mike, Charles,

Thank you for your time.

Mike, roasting as the biological CCP. This is the citation I found to justify.

http://labspace.open.ac.uk/mod/oucontent/view.php?id=451998&section=8.4.3

Research of the roast logs for January 2014 showed the lowest final roast temperature obtained as 390°F, far above sterilization temp of 275F.

The destoner for Physical CCP. Our verification consists of finding roasted coffee in the catch basin, meaning anything more dense will be in eliminated, i.e. glass, stone, metal. For Iess dense materials (wood, etc) I use "CFIA (Canadian Food inspection Agency) extraneous materials guidelines:" which states a 2mm threshold. Grinding easily covers this. It does not help with roasted whole bean coffee.

Charles, I used the USDA "Guide Book for Preparation of HACCP Plans" for methodology. Are you saying I should post the actual flow chart and hazard analysis I prepared? I am not sure if I should, since I have been unable to find a single example to compare against. Hence my decision to join IFSQN.

Thanks for the links and thread. I have to admit to not understanding what "tangential to OP" means.

Regards,

Bruce Z

Hi Bruce,

 

 

I have to admit to not understanding what "tangential to OP" means.

I think Charles just means that if you put the word 'coffee' in the title of the original post-you would get more responses!

There is a fair bit of debate over whether roasting of coffee is infact a ccp (due in the main, to the fact that the coffee is going to be brewed before use) -see this letter from the National Coffee Association to FDA (re FSMA)FSMA Comments 7-31-13.pdf   215.62KB   414 downloads 

(TBH-like Charles I was expecting OTA to figure in there somewhere (there is some interesting(to me) info on acceptable OTA limits in the attacheded1939e.pdf   649.33KB   252 downloads 

Mike

Dear bzuelch,

Thks for the sources / details posted.

A few comments -

(1) I appeciate coffee is a different commodity type but the roasting process is now somewhat "famous" due to its linkage with items like almonds, peanuts in respect to micro. hazards.

(2) Yes. Mike correctly interpreted my "tangential"  allusion. :smile:

(3) As per my previous attachment, I had deduced that FSMA were only interested in Salmonella. Does this not pre-define your required conclusion ? Or perhaps it represents the minimum "official" CCP (ie one) but with further additions  depending on yr own  process ? (I noticed the term "CCP" is noticeably absent from Mike's attachment). This practice is a standard feature of textbook haccp, ie the final result must relate to the specific process involved. This is the reason I suggested you post yr process/operating data (where relevant, like the roasting conditions).

(4) Assuming yr quoted 390degF represents a core temperature / largest bean size handled, i agree that a 5-6D reduction in any salmonella present should be well exceeded (as also indicated in Mike's 1st attachment). I fear the letter is probably optimistic regarding aspects such as  validation being un-neccesary.

(5) I (sadly?) rather doubt that the FSMA will be swayed by Canadian Guidelines for items like metal contamination inasmuch as the current USFDA viewpoint is rather long-established plus AFAIK there is always a fallback in USA onto the "adulteration" category / voluntary withdrawal options.

(6) The USDA book (ca, 1997?) which you refer to as a reference for haccp is, I believe, now regarded within USA as obsolete. (I'm basing my comment on a previous lengthy thread here regarding haccp programs for USA meat processors). Maybe quote with caution. (There is a recent FSIS haccp text, ca 2013-14, but probably also oriented to meat/poultry).

(7) Mike's / attachment comment regarding "brewing" is a valid point for debate but may well, IMO, be regarded by FSMA as a "red herring" in this particular case.

(8) I noticed Mike's attachment was over a year old, one would have thought the official response would be out by now ?

(9) Like Mike, I'm surprised that there seems to be a lack of interest in OTA.

(10) Apologize for my ignorance but do FSMA have jurisdiction over (ie above) both USFDA and USDA ? Seems sort of un-American ? :smile:

Hope the above comments interesting. I am a little cautious in opinions since I am ignorant as to the precise intended / stategic relationship between the FSMA and the processors, eg who is yr haccp plan going to be appoved by in the future ? ( presumably it's USFDA at the moment).

Rgds / Charles.C

The plant I worked at just recently received certification in SQF Level 2.  We are now pursuing Level 3 certification.

This is my opinion:

  CCP (Critical Control Point) = controlling food safety hazards.

  QCP (Quality Control Point) = controlling quality hazards (defects).

CCP is the last point where you can control a particular food safety hazard.

The plant I worked at just recently received certification in SQF Level 2.  We are now pursuing Level 3 certification.

This is my opinion:

  CCP (Critical Control Point) = controlling food safety hazards.

  QCP (Quality Control Point) = controlling quality hazards (defects).

CCP is the last point where you can control a particular food safety hazard.

Dear CMHeywood,

Any thoughts on coffee ?

Rgds / Charles.C

Hi Bruce,

 

I think Charles just means that if you put the word 'coffee' in the title of the original post-you would get more responses!

 

There is a fair bit of debate over whether roasting of coffee is infact a ccp (due in the main, to the fact that the coffee is going to be brewed before use) -see this letter from the National Coffee Association to FDA (re FSMA)FSMA Comments 7-31-13.pdf

 

(TBH-like Charles I was expecting OTA to figure in there somewhere (there is some interesting(to me) info on acceptable OTA limits in the attacheded1939e.pdf

 

Mike

I would not assume coffee would be brewed before use.  It is used in many other ways without a kill step and consumed.

I would not assume coffee would be brewed before use.  It is used in many other ways without a kill step and consumed.

Yes, thanks for that.

This aspect is, or if not should be, required to be clearly stated in the introductory portion of a typical HACCP Plan.

Rgds / Charles.C

I would not assume coffee would be brewed before use.  It is used in many other ways without a kill step and consumed.

Yes, thanks for that.

 

This aspect is, or if not should be, required to be clearly stated in the introductory portion of a typical HACCP Plan.

 

Rgds / Charles.C

This is what our Haccp plan contains:

All products produced by ERI can be grouped as "Roasted, Not Potentially Hazardous Food”. Coffee, by virtue of processing (grinding) and use (brewing), falls well within acceptable limits for HACCP. All coffee produced by ERI is sold for consumption via brewing. ERI produces no RTE foods.

I would think raw material receiving would contain a CCP related to mycotoxins, especially aflatoxin control. Coffee is one of the foods prone to mycotoxin contamination and this of course is a significant food safety risk.

The risk of mycotoxin contamination would also hold true for storage unless your packaging used for the roasted coffee is effective in controlling moisture absorption and subsequent mold growth.

Note that the roasting process is not effective in destroying many types of mycotoxins, thus if they are above the limits in the unroasted beans, roasting will not eliminate or reduce the danger to safe levels.

Hope this helps

Dear srose,

Do you expect mycotoxins to survive 200degC?

added later - after a little googling it appears that  "roasting" up to 200degC may be inadequate to eliminate some mycotoxins.

http://www.fao.org/a...ine/0607sp1.htm

http://www.mycotoxin...science_cs.html

from a safety risk POV, specific, coffee linked epidemiological data seems scarce, ie i couldn't find any from a quick google.

Discourses on the potential mycotoxin consequences for coffee drinkers are predictably numerous but inconclusive. Can try these 3 links if interested - 

http://suppversity.b...coffee-are.html

http://authoritynutr...in-coffee-myth/

http://cooking.stack...n-they-be-avoid

Rgds / Charles.C

Hi Bruce,

Here's my over late addition to this discussion. While managing (Food Safety and Quality)at a coffee roasting facility; these are a summary of the key challenges I encountered with respect to HACCP. Now, remember your original post was in the context of FSMA. Therefore, I am communicating with a view to converting HACCP to HARPC because coffee will fall under FSMA and HARPC.

The food safety plan I inherited at hire was a HACCP plan according to Silliker who performed the GMP audits. However, it had no CCP's, only/GMP programs. The Silliker auditor told me a HACCP plan without CCP's was really a Food Safety Systems Management Plan. I believed him until later I learned it was one of those perennial points of contention. Now, years later in retrospect, it definitely should have had foreign matter, metal detection or x-ray as a CCP because anything 6mm or greater is a choking hazard. The caveat was that the facility sold some very finely ground coffee as an ingredient for chocolate, but he Plan stated that the coffee was sold for brewing only. Obviously this was a major faux pas in hazard analysis!

Coffee is sometimes processed on the rain forest floor and can have things like wire, bottle caps, even the toys the workers' children play with and the like.  Debris was our most frequent customer complaint. Lots of broken coffee grinders when the burrs hit a chunk of debris.  In the name of continuous improvement there should have been far better preventative controls. I discovered that the seives were in such poor condition, they probably added more metal debris than they extracted. Also, I discovered the magnet traps had lost most of their magnetism. Probably my most significant achievement there was to get new seives and neodynium magnets. I also now believe that some of the debris came not only from the raw coffee, but from the lack of preventative controls on repairs, preventative maintenance and intrusive maintenance activities. Oddly enough, my tracking and trending of debris incidence was highly correlated to specifically Colombian Coffee over coffee from any other world local.

The process of getting the coffee cherry fruit flesh off the bean and then drying the coffee can lead to various species of mold that contaminates the raw bean with mycotoxins like sterigmatocystin, OTA, and aflatoxin. Improperly dried coffee can also mold while enclosed in the sea-tainer or rail car or trailer. The coffee can be drenched in condensate! I think there needs to be very definite preventative controls for rejecting the coffee at this juncture. None of these mycotoxins are completely denatured during roasting. IMO, testing the lots of coffee ought to be a CCP under HACCP and a preventative control under HARPC. Some kind of validated sampling plan for test samples needs to be developed. As far as I can ascertain, the European import requirements are much more robust than in the US. Where do you suppose the coffee that Europe rejects for mycotoxins gets sold? In the two week period after giving notice I got approval to order a fluoroscope, but only because the client that put the facility on the map insisted as part of their audit findings CAPA.

I would also distrust how pesticides may have been used in close proximity to the beans in order to combat Indian Meal Moths and other pests, so pesticide residue testing may be in order. This might be one of those risks that you investigate by performing some initial rigorous testing and then later adjust in accord with the results. 

Another little know practice that took me by surprise a few months into my tenure was that dark roasted coffee like French and Italian Roast is so hot when dumping it from the roaster, that it will catch fire unless water is dumped onto the coffee beans in the roaster just moments before the coffee is dumped out for cooling. For our process it amounted to about 10 gallons of water. There ought to be preventative controls for water safety.

Yet another discovery for me was the fact that the modified atmosphere gases used to flush oxygen from the bag when filling was from a nitrogen concentrating device that was on a concrete pad outside by the alley. Consideration needs to be given for preventative controls for both the purity of the air at the point of use and for the vulnerability of the MAP gases and related appliances for food defense. 

The carboys, jerrycans and drums of artificial flavors used to flavor some coffees deserve considerations for preventative controls in a similar manner that one might give to the cleaning chemicals a facility uses for sanitation.

In the postings of this thread some mention was made of microbial testing. There may be some merit to validating the absence of the need to perform microbial testing, especially on lightly roasted coffees. On the other hand, there may be some merit to performing some finished product (post roast) microbial testing. In the case of this facility, it was yet another assumption that never should have been made.

The final issue I would bring up is that the process of grinding is a food defense "vulnerability" that at the very least requires a risk assessment for the defense of food plan. 

With respect to FSMA, I am given to understand that the Sanitary Transport Rule will have NO exemptions for either USDA or FDA HACCP facilities as the other Rules do and that it will apply to rail cars as well as trailers and trucks. IMO I would plan on having specific contractual agreements with the entities "transporting" that address the condensation I spoke of above. You need to be able to reject the coffee at the port, rail car or trailer and put the onus on the supplier and transporter in the eventuality that condensate is not controlled.

Great pains were taken to assure the quality (taste) of the coffee through blind tasting by qualified panels and that the facility actually received the self-same coffee purchased from wherever in the world we first discovered it, but the assumption that the coffee was low risk because it would only be brewed in a coffee maker was a de facto excuse to dismiss responsibility for food safety concerns.

Am currently working on a roasting facility that gets green clean coffee from millers and my assessment is as follows.

Roasting is a QCP and destoning a CCP. Metal Trap A CCP

Mycotoxin an oPRP through monitoring moisture to be lower than 12.5%

I would like to request for a copy of your hazard analysis. 

Am currently working on a roasting facility that gets green clean coffee from millers and my assessment is as follows.

Roasting is a QCP and destoning a CCP. Metal Trap A CCP

Mycotoxin an oPRP through monitoring moisture to be lower than 12.5%

I would like to request for a copy of your hazard analysis. 

hI drisle,

you are replying to a 2-year old thread. May be a delayed answer.