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HACCP Plan Guidance

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staci mccarvey

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Posted 29 November 2017 - 09:43 PM

I work for a small company that produces a variety of sauces, that all have a kill step. The owner's son has formulated a product that is made of oils, sunflower lecithin and a few flavor extracts. The problem is, at least what I can forsee, is this is intended to be Ready-To-Drink, shelf stable but there is not a kill step. The product is just mixed and then bottled, is this acceptable? They want to add Cacao Powder to the recipe and I do not have any experience with these particular items so I could use some advice or guidance if anyone has any! Thank you!



FurFarmandFork

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Posted 30 November 2017 - 03:57 PM

The owner's son has formulated a product that is made of oils, sunflower lecithin and a few flavor extracts. The problem is, at least what I can forsee, is this is intended to be Ready-To-Drink, shelf stable but there is not a kill step. 

 

 

So not refrigerated, is it acidified? If the water activity (not moisture) of the final product is not under 0.85 this would either be an acidified food or a low acid canned food, and you need to file a process with FDA to legally produce it.

https://www.fda.gov/...ACF/default.htm

 

Example warning letter if they don't think it's a real thing: https://www.fda.gov/...s/ucm417281.htm

 

Dressings are a common violator of LACF and AF regulations since they previously had an exemption but no longer do.


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staci mccarvey

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Posted 30 November 2017 - 04:16 PM

Yes, the water activity is well below that. We have been running between 0.41 and 0.46 water activity, that also adds to my need for help.



FurFarmandFork

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Posted 01 December 2017 - 12:13 AM

Hmm, well if it doesn't pose a risk of spoilage then and it's expected to be pathogen free (demonstrated by raw material, environmental, and finished good testing), then there's not really a reason that you couldn't make it..you mentioned it's ready to drink? Is this a supplement type item?


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Ryan M.

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Posted 07 December 2017 - 11:21 PM

The risk comes with your raw materials.  Even a low water activity in the product does not make it safe throughout the process.  For example, if your customers do something to raise the water activity and there is dormant pathogens, or spores, then BOOM you got a problem.

 

As far as adding cocoa powder....be ready for spoilage problems, mold and yeast problems.





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