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#1 Andy_Yellows

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Posted 25 September 2018 - 09:56 AM

Hi all,

 

Trying to get on top of a micro sampling plan for cut RTE vac-packed vegetables and unpasteruised citrus fruit juices (no additives, just squeezing and bottling) produced on our site. I've looked at a number of sources to try and figure out which tests we do and don't need to run and it all seems a bit confusing. Our FS standard only requires E.Coli 0157 and Listeria, whereas the Guidelines for Assessing the Microbiological Safety of Ready to Eat Foods Placed on the Market document details Enterobacteriaceae, ACC (which HPA came and performed tests for on our products) etc while our history of micro sampling, set up by the previous incumbent here, includes clostridium perfringens and bacillus cereus among others which sounds, on the face of it, unnecessary.

 

Is anyone able to clarify which tests are legally required, which ones are desirable and which ones we can probably do without given the nature of our products?

 

Many thanks in advance,

 

Andy


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#2 Scampi

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Posted 25 September 2018 - 06:30 PM

Andy

 

You're predecessor was right particularly for the juices........in the USA you cannot produce juice without pasteurizing as pH alone has proven to not be enough.

 

https://www.fda.gov/.../ucm2006803.htm

 

clostridium perfringens and bacillus cereus should be checked if your not pasteurizing

 

I wish I could help more, but it appears that Brexit has made a bit of a mess for you brits to deal with right now.....i couldn't find anything specific!!!


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#3 Charles.C

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Posted 26 September 2018 - 11:25 AM

Andy

 

You're predecessor was right particularly for the juices........in the USA you cannot produce juice without pasteurizing as pH alone has proven to not be enough.

 

https://www.fda.gov/.../ucm2006803.htm

 

clostridium perfringens and bacillus cereus should be checked if your not pasteurizing

 

I wish I could help more, but it appears that Brexit has made a bit of a mess for you brits to deal with right now.....i couldn't find anything specific!!!

 

Hi Scampi,

 

Above I believe not quite complete.

 

Most of the juice sold in the United States is pasteurized (heat-treated) to kill harmful bacteria. Juice products may also be treated by non-heat processes for the same purpose. However, some grocery stores, health food stores, cider mills, farmers’ markets, and juice bars sell packaged juice that was made on site that has not been pasteurized or otherwise treated to ensure its safety. These untreated products should be kept under refrigeration and are required to carry the following warning on the label:

WARNING:This product has not been pasteurized and therefore may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems. 

However, FDA does not require warning labels for juice or cider that is sold by the glass – for example, at apple orchards, farmers’ markets, roadside stands, juice bars, and some restaurants

 

https://www.fda.gov/...s/ucm110526.htm

 

@ Andy - Re- Juices - I would have thought the FSA are the authoritative answer to "required" ? (possibly  >> HPA/s compilation assuming that unpasteurised juices are listed ??)

 

Usually, "required" = (minimally) desirable. :smile: (ignoring cost aspect)

 

RTE vac-packed items presumably (initially) fall within the FSA C.botulinum regs variously posted here.


Kind Regards,

 

Charles.C


#4 Scampi

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Posted 26 September 2018 - 12:33 PM

IMHO the FDA has it's hands tied..........it's trying to make a really good set of regulations but each state pushes back hard and says NO we don't want that here or but we've always.........

 

I also happen to think the new acidified foods regs are crazy nuts............we produce an acidified food (not juice or sauce) and scientifically our product would be safe (see also pickle bibliography) even if we didn't heat treat it (we do) but if I were in the USA i would have to go to better processing school AND file my product with the FDA and NONE of the USDA ARS scientific research would be applicable!

 

The FDA issued draft guidance in 2014 that has since been retracted BUT inspectors are still using it!!!

 

When it comes to fresh from the farm milk, juice, eggs, cider etc etc etc every individual should be able to make there own decisions----you have chosen to go on farm and consume something...............when you go to the grocery store that is different...........business' are paying for you to see there product...........so it needs to be safe every time

 

In a lot of respects I feel really badly for our US colleagues........that vast majority want to do the right thing but they've not been given any of the tools they need to do the job!


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#5 pHruit

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Posted 26 September 2018 - 01:33 PM

Hi Andy,

Have you had a look at Annex I of Regulation (EC) 2073/2005?
The tables have a specific entry for unpasteurised juices.

I did also see a draft amendment to this earlier in the summer that you can view on the EC's website here, although I don't recall there being any substantive changes that would affect your particular question: https://ec.europa.eu...2018-3346568_en

I think part of the challenge you're going to have here is that the FSA's approach and indeed much of EU regulation for some product types seems to be more of the form "this is roughly what we'd like as an end result, and it's up to you to decide how to accomplish it and demonstrate that you're doing so", whereas I always got the impression that e.g. the FDA is far more prescriptive, as Scampi's post above also seems to suggest ;)

Are you members of the British Soft Drinks Association or British Fruit Juice Association? If so then I'd make an enquiry with them - unfortunately this isn't covered in the general Technical Guidance document that the former publishes, but there is almost certainly a committee and/or member who will have already considered this specific question.

Failing that, try asking your EHO - they generally like questions that come from businesses trying to improve and comply and it's good to have an open dialogue with them; makes it so much easier in the unfortunate event of any problems!



#6 Charles.C

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Posted 26 September 2018 - 02:05 PM

Also see this thread -

 

https://www.ifsqn.co...teurised-juice/

 

eg post 11.

 

Hi Andy,

 

"juices" seems to be a long-term project.

 

The thread above (and partially the attachment in post 11) suggest  taking UK pasteurised specs (eg HPA) as an initial  target. I guess there is enough data accumulated by now to know if such a compliance is feasible (or not) ??.


Kind Regards,

 

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#7 Andy_Yellows

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Posted 27 September 2018 - 10:28 AM

Hi guys,

 

Thank you all for your detailed and informative responses to my question. I'll make a point of reading the material you've all kindly referenced and see how it affects us going forward. The subject all seems very ambiguous for something so important to be on top of.

 

Regards,

 

Andy


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#8 Scampi

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Posted 27 September 2018 - 12:30 PM

NOTE: i was doing some reading yesterday and facilities (restaurants/food stalls) have been shut down for reasons INCLUDING not posting the risks associated with unpasteurized juice

 

https://www.foodpois...s/juice-recall/

 

https://www.foodpois...ed-apple-cider/

 

I understand that the law in the UK is very different in some respects to what we experience in Canada and the US---i'm thinking washed/unwashed eggs of the top of my head........so perhaps your rules are different in this regard


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#9 pHruit

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Posted 27 September 2018 - 01:02 PM

Our rules are indeed quite different!

For juices in general there is no specific requirement to state unpasteurised in the UK. Indeed for a while the guidance was that pasteurised juices should say "pasteurised" on the basis that it is an extra process to which the product has been subjected and consumers should be informed about this as they may not expect it. This was removed though, as well over 99% of juice in the UK is pasteurised so consumers can't realistically expect it to be otherwise. Whether these statements mean anything to the average consumer is alas not a something that seems to be considered in much of the labelling guidance or the relevant regs ;)

 

Freshly squeezed juice is specifically defined as product that is to be consumed, and have a use by/BBE date, no more than 14 days from production and has it's own additional rules beyond "normal" juices. In this case the guidance really is the exact opposite of the US - the regulatory view is that consumers would expect this to be unpasteurised, so it should carry the description "freshly squeezed pasteurised orange juice" or similar if it has been pasteurised.

We tend to only see "unpasteurised" on juice labels where it's part of the brand image, either to appear more natural (which is tenuous) or on the basis of taste (which is more reasonable).



#10 FurFarmandFork

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Posted 28 September 2018 - 11:48 PM


 

The FDA issued draft guidance in 2014 that has since been retracted BUT inspectors are still using it!!!

 

 

 

 

Yeah, happens way too much. In this instance I tend to forgive them though. The guidance was SOO needed that a bunch of State-level regulators adopted it at the state level, so even though FDA retracted it (and is trying really hard to erase it for some reason), it's still valid at the state level.

 

And the vast majority of "FDA audits" are conducted by contracted state inspectors. Hence why they have reason to use the regs one day, then not another when the jurisdiction of the audit changes.  :dunno:


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#11 Charles.C

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Posted 29 September 2018 - 09:53 AM

Hi all,

 

Trying to get on top of a micro sampling plan for cut RTE vac-packed vegetables and unpasteruised citrus fruit juices (no additives, just squeezing and bottling) produced on our site. I've looked at a number of sources to try and figure out which tests we do and don't need to run and it all seems a bit confusing. Our FS standard only requires E.Coli 0157 and Listeria, whereas the Guidelines for Assessing the Microbiological Safety of Ready to Eat Foods Placed on the Market document details Enterobacteriaceae, ACC (which HPA came and performed tests for on our products) etc while our history of micro sampling, set up by the previous incumbent here, includes clostridium perfringens and bacillus cereus among others which sounds, on the face of it, unnecessary.

 

Is anyone able to clarify which tests are legally required, which ones are (a) desirable and (b) which ones we can probably do without given the nature of our products?

 

Many thanks in advance,

 

Andy

 

Hi Andy,

 

Re - red

 

I anticipate that any legal requirements are likely to be safety rather than quality related.

 

However, from the previous posts the strict answer appears to be -

 

(a) None.

(b) See (a)

 

Nonetheless i anticipate that responsible producers will be interested in assurance that their product is "free" (~ undetectable) of recorded safety hazards such as discussed in the brief extract below (ex my previous attachment, relatively old but probably still relevant).

And possible indicator organisms.

And quality micro.factors of course.

 

Attached File  unpasteurized juice safety hazards.pdf   443.5KB   5 downloads


Kind Regards,

 

Charles.C





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