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Specialty Coffee Roasting HACCP/HARPC and FSVP

HACCP HARPC FSMA Coffee GMP FSVP specialty coffee

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#1 onascaleofonetobotulism

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Posted 06 June 2018 - 03:20 PM

Good morning,

 

Over the past 12-14 months, I've taken over the implementation of GMPs and the overall Food Safety Plan at a small-to-midsize coffee roaster in the Midwest USA. 

 

One of my biggest challenges has been understanding supplier approval/verification, and how it applies to green coffee. We are NOT an importer ourselves, but work with 8-12 different midsize American importers of green coffee. We source Specialty Coffee exclusively; however, the origins are drastically varied, from East Africa to Southeast Asia to a dozen countries in Central and South America.

 

In discussions with one of our larger suppliers, I was told that the FSVP rule for green coffee importers was practically non-existent, as the food product is technically controlled downstream (by us) as far as microbiological concerns; when it came to mycotoxins, there appears to be no actual regulatory limit within the US for coffee. Additionally, no one in our industry appears to know anything or be asking anything about pesticide residues. Our supplier suggested that they are therefore not responsible for any kind of FSVP requirement as of yet.

 

My questions is: would a HACCP plan be required, if the "cook step" is something that the product literally has to go through regardless, in order to be sold as roasted coffee? If so, would I actually need to verify the monitoring of that "cook step" for each batch? A coffee that has not reached the appropriate roasting temp (typically in excess of 300 degrees Fahrenheit) or the correct amount of time (anywhere from 12-18 minutes) will not appear properly roasted, or if it did, would not meet its taste profile during quality (sensory) checks. 

 

Whether or not HACCP for coffee roasting would require active verification of roasting temps, what about the overall HAPRC regulations? Generally, roasted coffee is low risk for contamination hazards, because it will normally (9/10 times) be brewed with near-boiling water, and also there is no real history of micro concerns. 

 

I do routine swabs for salmonella in processing areas, but not on Zone 1 equipment, since that would necessitate precautionary holds. I don't think much more is necessary, but can't find anything more concrete, source-wise, to validate my position (unlike, say, the thermal processed acidified Chai products our sister company does, which I also supervise, and which has clear FDA guidelines re: acidification, temperature, etc., and we have our process authority letter,etc.).

 

Am I just being paranoid, or amI missing something in regards to the coffee roasting and packaging process? We have GMPs, we have Sanitation, Chemical, and Allergen controls (which I'm aiming to strengthen), but is there anything else I should worry about?



#2 Scampi

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Posted 06 June 2018 - 04:46 PM

https://dailycoffeen...ernization-act/

this article says coffee fails into the category of food, but is inherently safe by nature of the process/use

 

Perhaps this association is worth joining for this specialty information you'll have access to!


Because we always have is never an appropriate response!


#3 Scampi

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Posted 06 June 2018 - 04:47 PM

www.fda.gov/downloads/food/guidanceregulation/guidancedocumentsregulatoryinformation/ucm526507.pdf

 

This FDA document speaks to coffee roasting specifically


Because we always have is never an appropriate response!


#4 onascaleofonetobotulism

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Posted 06 June 2018 - 05:15 PM

Scampi-

 

Thanks, but I have already seen the Small Entity Compliance Guide and that article from Mike Ebert. The former only mentions coffee beans in the context of a small farm or farm-type facility, and the fact that the beans are subsequently "controlled" at a later stage by a downstream entity (i.e. roasters like us).

 

I've looked at the available research the Specialty Coffee Association displays on their website, and what does pertain to standards and practices is all in the form of recommendations and guides for green coffee processing, or brewing--but not roasting/manufacturing.

 

There seems to be a sort of consensus that it just isn't worth talking about, since it's assumed that roasted coffee HAS to be safe to be consider "roasted", and since most of it is marketed for hot brew methods, there isn't even that much in the way of strict finished product handling standards.



#5 Scampi

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Posted 06 June 2018 - 05:48 PM

I understand your concern, and I applaud it, but there are some products out there to which the risk just isn't there!  

 

I make an acidified food, so we have a kill step as well, but as long as time/temp and equilibrium pH are all within range, our product is naturally safe (heck, we've all been eating them for 1000's of years) 

 

 

I would then compile a very through risk assessment, including researching any recalls/withdrawals that have every occurred from roasted coffee. Then, I would send out samples of FG to VALIDATE what you are thinking, that your product is safe by it's nature of processing.

 

Question: Are coffee beans included / covered in the new FSMA regulations?

Answer: Coffee beans are listed as “rarely consumed raw” and excluded from being subject the Produce Regulations, however, they are NOT excluded from the Good Manufacturing Practices regulations or requirement for processing in a sanitary environment.  Language around exclusions for coffee beans indicate that they must go through a “kill step” such as the roasting operation or process, before consumption… but a food processor who then takes the roasted coffee beans and uses them as an ingredient to make a “cold brewed coffee beverage” would be subject to all of the same Food Safety regulations as any other food processor because they are handling / processing the ingredient AFTER the “kill step” where it could become unsafe for consumption from environmental exposure.

Reference: https://www.fda.gov/...A/ucm247559.htm

Note: “Tea leaves” are NOT included in the list mentioned above – there is NO specific exclusion of tea from any of the food safety regulations.

Question: Are there any effective kill steps for the coffee roaster, consumer or tea consumer considering the commodity (tea) and processed commodity (roasted coffee) may have been served after having added water that approaches the boiling point?  

Answer: There is no FDA approved kill step for coffee or tea at this time.  The FDA would require proof that the process of steeping (tea) or roasting/brewing (coffee) would eliminate potential microbiological threats.  

Note: There have been no studies or analyses that provide proof that coffee or tea with a pathogen prior to the process had been eliminated due to the processing.

Note: Given the fact there is no history of food poisoning outbreaks for hot brewed coffee and very little history for tea, regarding microbiological hazards due to a pathogen, this could be categorized as historical data defending the method of hot brewing. 

What does this mean to you – the roaster, coffee consumer and or tea consumer.

- This means that at this point in time having none or very little history of a food hazard due to a pathogen from hot brewed coffee or hot steeped tea, there is no required or mandated “kill step” regarding a specific temperature needed for roasted coffee or specific degree in hot brewing your favorite coffee or tea drink. Traditional brewing methods are deemed safe.  

www.royalnylab.com/blog/2017/10/27/fsma-part-2-roasting-and-brewing

 

Because we always have is never an appropriate response!


#6 onascaleofonetobotulism

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Posted 06 June 2018 - 08:21 PM

Would it be reasonable, then, to not even have a HACCP, but rather a HARPC that specifies roasting as a "preventive control" not requiring verification, as it is an inherent part of preparing the beans for usability, and cannot be inadequately accomplished? 

 

As for cold brew, hypothetically, what kind of preventive controls might require implementation following the roasting of the coffee? I am tempted to say that, like the "historical evidence" logic used for hot tea and hot coffee, there is similarly a wealth of anecdotal evidence to suggest that people cold brewing for themselves practically never use the coffee in such a way as to pose a serious food safety hazard--if it "goes off" because of poor handling or leaving it out too long, then it generally tastes/smells off.

 

However, if roasted coffee were used internally by a company to make cold brew to be sold--what controls might be feasible/expected, assuming no further kill step?



#7 Scampi

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Posted 07 June 2018 - 08:20 PM

Ah, cold brew coffee requires a full HACCP program as you could introduce pathogens back in and there may not be a kill step post brew

 

https://www.fda.gov/...s/ucm576809.htm

 

https://www.dripsand...cess-authority/

 

https://foodsafetyte...od-regulations/

 

https://www.dripsand...w-distribution/


Because we always have is never an appropriate response!


#8 onascaleofonetobotulism

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Posted 07 June 2018 - 08:38 PM

With coffee typically being considered a low hazard food, with very little possibility of microbial growth, would a cold brew product that is kept refrigerated AND in a pressurized, low oxygen package be much at risk? My understanding of the Death Wish recall was that they had been putting out ostensibly "shelf stable" product. Would refrigerated product help to alleviate the C. bot concern, in light of the lack of any real nutrients or rich oils for the bacteria?



#9 Charles.C

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Posted 07 June 2018 - 11:15 PM

Hi onascale,

 

I know little about this topic other than Ochratoxin in coffee is apparently unavoidable however the classic advice here regarding yr informative OP is to directly ask the FDA what their position actually  is. The "Coffee Association" mentioned in Posts 2/3 comes over as (so far) rather blasé on HACCP/FSMA but perhaps i am being unfair. Just for comparison i noticed this website comment -

 

https://www.trabocca...ernization-act/

 

You may find this 2014 thread of some interest although I suppose was only then on the fringes of FSMA -

 

http://www.ifsqn.com...omes-re-coffee/

 

PS - the "comforting" terminology of a "kill step"  is often revealed to have some caveats when scrutinised under the haccp microscope. However a (highly) satisfactory long-term safety record also carries a lot of weight.


Kind Regards,

 

Charles.C


#10 Scampi

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Posted 08 June 2018 - 06:08 PM

refrigeration may help, but if your pH is encroching on 4.4 may not be enough

 

I would follow Charles' suggestion and contact the FDA directly..........after all the whole idea behind a HACCP program is to identify and control/eliminate hazards to avoid sickness, death and/or recalls


Because we always have is never an appropriate response!


#11 ECFISCHER

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Posted 13 August 2018 - 07:48 PM

I feel your pain in regards to FSVP. I too handle FS/ Reg Comp for a medium sized coffee roaster in the Midwest.

 

FSVP plans vary drastically, some importers actually are trying to comply with the regulation as written, some, as you pointed out, when asked for their FSVP plan send you an agreement to sign that you'll control everything; including hazards that can only be controlled on the farm level.

 

Unfortunately/ fortunately as far as compliance is concerned I believe both types of plans are acceptable. Our HARPC plan has no CCPs/ PPCs. Historical data shows coffee to be very low risk for microbial hazards. No action level has been set YET for OTA in the US, and studies have shown most pesticide residue is destroyed during the roast (organochlorine pesticide residues in raw and roasted coffee and their degradation during the roasting process).

 

When it comes down to it coffee is low risk; the FDA isn't targeting roasters and they certainly aren't targeting importers, hence we have to take them at their word that they're complying with regulations.

 

P.S. It is extremely hard to get answers out of the FDA. If they do respond it will most likely be years later and as vague as the regulations themselves.


Edited by ECFISCHER, 13 August 2018 - 07:57 PM.


#12 012117

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Posted 14 August 2018 - 12:17 AM

On my experience, we are more concern on coffee before it is roasted as the moulds that my generate OTA will not likely be killed by the roasting and OTA will not likely be lowered by any processing condition (IMHO). We don't do salmonella, implement prerequisite programs (but focus mostly on moisture control). Since, it is a long way back since I was in coffee, I forgot already what we sample for pathogen monitoring. However, agree with Charles that if there is confusion, may want to contact FDA.



#13 Sussy

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Posted 05 November 2019 - 06:06 PM

I too handle FS/ Reg Comp for a medium sized coffee roaster in the Midwest.

 

Thank you for the information. What documents do you get from your suppliers?

 

Do you do environmental or food contact microbiological testing?



#14 ECFISCHER

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Posted 05 November 2019 - 08:48 PM

Thank you for the information. What documents do you get from your suppliers?

 

Do you do environmental or food contact microbiological testing?

 

We require Letters of Guaranty from our importers in addition to their FSVP documents, and a COA for each lot of GB. COA's designate grade and MC as mentioned by 012117 above, which are very useful for verifying suppliers.

 

As far as micro is concerned we do not perform or request micro on every lot. We do have an environmental monitoring procedure in place: typical 4 zone: for salmonella and APC. We do occasionally test end product for salmonella to validate the system is working.







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