14 replies to this topic

[selmaassili]

hello all,

 

Among our ingredients there are the conservatives, such as sorbic acid and potasuim sorbate, logically there is no microbiological risks because they are Antimicrobial preservatives, fungistatic agents (www.fao.org/ag/agn/jecfa-additives) so there is no need to ask our supplier  to provide us with microbiological data ? 

 

and also Vitamins we are not receive the microbiological data, is it necessary ?

 

thank you 

[Charles.C]

hello all,

 

Among our ingredients there are the conservatives, such as sorbic acid and potasuim sorbate, logically there is no microbiological risks because they are Antimicrobial preservatives, fungistatic agents (www.fao.org/ag/agn/jecfa-additives) so there is no need to ask our supplier  to provide us with microbiological data ? 

 

and also Vitamins we are not receive the microbiological data, is it necessary ?

 

thank you 

 

Hi Selma,

 

It relates to clause 3.6.

 

Personally, unless obviously unrelated, i request a micro. spec. for "ingredients" purity aspect. For potassium sorbate you can find specs. with/without micro, eg see below -

 

 spec1 - Potassium-Sorbate.pdf   1.2MB   154 downloads

 spec2 - Potassium Sorbate Granular.pdf   61.88KB   78 downloads

[selmaassili]

thanks for the reply,

 

so you suggest that i need to ask for microbiological spec anyway.

[Charles.C]

thanks for the reply,

 

so you suggest that i need to ask for microbiological spec anyway.

 

Hi selma,

 

Yes. English idiom is - Nothing venture, Nothing gain.

[ViandGroup]

As an auditor and trainer, yes, you do need the Certificate of Analysis.

[Ryan M.]

Question...are you conducting any treatment to reduce or remove microbial (pathogen risk)?  If so, are these ingredients added before that step? 

 

This makes a big difference.  And sure...nothing ventured, nothing gained; however we usually are limited in resources so why waste the resource if the risk is minimal to nothing? 

 

What is really lost these days in terms of food safety and quality is assessing the actual value of your systems, programs, SOP's, activities you do on a day in and day out basis.  What would be the value you would achieve of broad assessment of micro risk in an ingredient that has very little risk and is added before any treatment to reduce or remove microbial (pathogen risk)?

[Charles.C]

 

Question...are you conducting any treatment to reduce or remove microbial (pathogen risk)?  If so, are these ingredients added before that step? 

 

This makes a big difference.  And sure...nothing ventured, nothing gained; however we usually are limited in resources so why waste the resource if the risk is minimal to nothing? 

 

What is really lost these days in terms of food safety and quality is assessing the actual value of your systems, programs, SOP's, activities you do on a day in and day out basis.  What would be the value you would achieve of broad assessment of micro risk in an ingredient that has very little risk and is added before any treatment to reduce or remove microbial (pathogen risk)?

 

 

Hi Ryan,

 

Perhaps I should simply have directed the OP to links such as these -

 

https://www.fda.gov/...s/ucm228269.htm

 

https://www.efsa.eur...ionsandguidance

 

https://en.wikipedia...Chemicals_Codex

[FurFarmandFork]

Hi  selmaassili,

 

I don't request a CoA for those ingredients, they're actively bacteriocidal against my target organisms. I request a CoC/specification for purity, and independently confirm purity once per year myself.

[selmaassili]

Hi  selmaassili,

 

I don't request a CoA for those ingredients, they're actively bacteriocidal against my target organisms. I request a CoC/specification for purity, and independently confirm purity once per year myself.

hello thank you for the reply , but i was wondering maybe i should ask also in CoA for heavy metals ?

[FurFarmandFork]

If heavy metals are a concern in your product, then yes. But if the purity specification already contains a contaminant limit (many of the FCC purity specs for food grade include a lead limit) then you already have that info.

[Charles.C]

Hi Selma,
 

hello all,

 

Among our ingredients there are the conservatives, such as sorbic acid and potasuim sorbate, logically there is no microbiological risks because they are Antimicrobial preservatives, fungistatic agents (www.fao.org/ag/agn/jecfa-additives) so there is no need to ask our supplier  to provide us with microbiological data ? 

 

and also Vitamins we are not receive the microbiological data, is it necessary ?

 

 

I originally interpreted the above query in two possible ways (a) to relate specifically to BRC7, Clause 3.6. This, together with clause 3.5  clearly (see quotes below) involves a  series of (BCPA) knowledge requirements regarding Safety, Regulatory, Quality, (b) generic but oriented to Food Safety, more specifically, haccp.

 

Which interpretation was correct Selma ? If neither then what ??

 

I would also reiterate that you are the customer, not the supplier. IMEX proposed "specifications" from the two ends of the food manufacturing chain are commonly of different, err, "scope" and likely with numerical variations.

 

If (a) -

 

Specifications for raw materials and packaging shall be adequate and accurate and ensure compliance with relevant safety and legislative requirements. The specifications shall include defined limits for relevant attributes of the material which may affect the quality or safety of the final products (e.g. chemical, microbiological or physical standards)

 

The above involves a series of ingredient knowledge requirements regarding  Safety, Regulatory, Quality,Process context.

 

If  (b) a generic answer is that the specification for items such as you refer should ensure that the ingredient is "Food Grade". (eg "safe to consume")

 

Unfortunately afaik there is no unique operational definition of "Food Grade". One answer often seen is that the specification should include "generic" requirements as listed in various recognised compilations such as the FCC, USP etc. Some narrower  US examples of possible reference sources were included in Post 7.

 

If none of the suggestions such as above assist, another option is to consult a database of typical BCPA, FS hazards for the ingredients involved such as the Canadian or US compilations often linked to on this Forum.

 

Morocco may well have its own (Regulatory??) preferences in which case yr answer is, at least,  Regulatory self-defined unless you are exporting.

 

Sometimes the answers provided in above options may differ either qualitatively/quantitatively or in their scope. If so, I tend to take the most conservative opinion unless there is a validatable reason to do otherwise. Just as an example of potential variations can see the 2 attachments in Post2.

 

Sometimes the feedback from above sources may IYO be visibly insufficient  in which case some personal judgement (ie additions) may be further required. This is a case-by-case situation.

 

Personally i normally go through all the above mechanisms when confronted with a new ingredient such as you mention and compare the results. And yes, it takes time. (TBH my first step is to do some Googling as per Post 2). I daresay other members have their own favorite procedures. Some retail customers IMEX have a formal on-line questionnaire system requiring inputs for a large range of standardised BCPA characteristics which are regarded as "essential". It's  part of their legally oriented  "due diligence" setup.

 

Interested to hear how you get on with yr 3 products in respect to routes such as the above.

 

PS - regarding yr comment of "heavy metals", IMEX this is a very frequent requirement of "Purity" specifications. For many historical reasons/disasters.

 

PPS - Regarding (a), the BRC7 clause 3.5.1.1 is also a major factor interlocking with the specification requirement -
 

 

The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:
•  allergen contamination
•  foreign-body risks
•  microbiological contamination
•  chemical contamination
•  substitution or fraud (see clause 5.4.2).
Consideration shall also be given to the signifi cance of a raw material to the quality of the fi nal product. The risk assessment shall form the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually.

[selmaassili]

Hi Selma,
 

 

 

I originally interpreted the above query in two possible ways (a) to relate specifically to BRC7, Clause 3.6. This, together with clause 3.5  clearly (see quotes below) involves a  series of (BCPA) knowledge requirements regarding Safety, Regulatory, Quality, (b) generic but oriented to Food Safety, more specifically, haccp.

 

Which interpretation was correct Selma ? If neither then what ??

 

I would also reiterate that you are the customer, not the supplier. IMEX proposed "specifications" from the two ends of the food manufacturing chain are commonly of different, err, "scope" and likely with numerical variations.

 

If (a) -

 

 

The above involves a series of ingredient knowledge requirements regarding  Safety, Regulatory, Quality,Process context.

 

If  (b) a generic answer is that the specification for items such as you refer should ensure that the ingredient is "Food Grade". (eg "safe to consume")

 

Unfortunately afaik there is no unique operational definition of "Food Grade". One answer often seen is that the specification should include "generic" requirements as listed in various recognised compilations such as the FCC, USP etc. Some narrower  US examples of possible reference sources were included in Post 7.

 

If none of the suggestions such as above assist, another option is to consult a database of typical BCPA, FS hazards for the ingredients involved such as the Canadian or US compilations often linked to on this Forum.

 

Morocco may well have its own (Regulatory??) preferences in which case yr answer is, at least,  Regulatory self-defined unless you are exporting.

 

Sometimes the answers provided in above options may differ either qualitatively/quantitatively or in their scope. If so, I tend to take the most conservative opinion unless there is a validatable reason to do otherwise. Just as an example of potential variations can see the 2 attachments in Post2.

 

Sometimes the feedback from above sources may IYO be visibly insufficient  in which case some personal judgement (ie additions) may be further required. This is a case-by-case situation.

 

Personally i normally go through all the above mechanisms when confronted with a new ingredient such as you mention and compare the results. And yes, it takes time. (TBH my first step is to do some Googling as per Post 2). I daresay other members have their own favorite procedures. Some retail customers IMEX have a formal on-line questionnaire system requiring inputs for a large range of standardised BCPA characteristics which are regarded as "essential". It's  part of their legally oriented  "due diligence" setup.

 

Interested to hear how you get on with yr 3 products in respect to routes such as the above.

 

PS - regarding yr comment of "heavy metals", IMEX this is a very frequent requirement of "Purity" specifications. For many historical reasons/disasters.

 

PPS - Regarding (a), the BRC7 clause 3.5.1.1 is also a major factor interlocking with the specification requirement -
 

hello charles , thank you alot for the reply ,

So i decide to combine the regulation (attach file) about specification for additives with the informations that i've got from the googling part to write the raw materiel specifications .

i only got one last problem is the difference beetwen things that i should put in the specification certificat and thing that i should ask for the certificat of analysis 

[Charles.C]

hello charles , thank you alot for the reply ,

So i decide to combine the regulation (attach file) about specification for additives with the informations that i've got from the googling part to write the raw materiel specifications .

i only got one last problem is the difference beetwen things that i should put in the specification certificat and thing that i should ask for the certificat of analysis 

 

Hi Selma,

 

So is this "project" directed to BRC ?

[selmaassili]

yes it's a BRC certification and i'm working on paragraph 3.5,such alot of work and requirement !!

[Charles.C]

Hi selma,

 

I enclose for yr interest 2 blank templates and one completed additional template (tp1-3)

 

 tp1 - Raw-material-specification.doc   57.5KB   116 downloads

 tp2 - product specification.pdf   194.02KB   98 downloads

 tp3 - example completed product specification.pdf   231.49KB   100 downloads

 

I also include a lengthy compilation of regulatory EC food additive specifications which contain, presumably, minimally required BCP data as was considered appropriate. There is no mention afai can see of allergenic characteristics. Most of the specifications are fairly concise and typically contain "CP" or "BCP" requirements.

 

 tp6 - Compilation EC Specifications for Food Additives,2012.pdf   4.28MB   63 downloads

 

(I noticed that the 2 compounds mentioned in yr OP have "CP" requirements but no "B".) Clearly "commercial" specifications choose to request further information as illustrated in the templates referred above and the examples in Post2.

 

I also attach three files which list/discuss the requirements of specification documents (tp4-5,7) -

 

 tp4 - developing finished product specifications.pdf   912.93KB   66 downloads

 tp5 - developing raw material specification.pdf   310.93KB   106 downloads

 tp7 - development raw material specifications.pdf   588.16KB   78 downloads