HACCP in coffee processing - roast/pack

is it okay if my company (coffee roasting manufacturer) determined CL of roasting with minimum 200 degree celcius and minimum 5 minute? and the roasting is CCP because E coli? my FSTL knows E coli can be reduced even with lower temprature of roasting. but i still didnt get it if only the source is from the workers like its not that CCP because the company is implementationing GMP and SSOP. after did verification flow process there are light, medium, and dark roast. i suggested my FSTL to mention the temperature and times range of each roasting's type in HACCP plan doc. i still haven't got references about its regulation. i need your point of view

Hi afdilazn,

Just some thoughts came into my mind..

 

Did your team have considered aflatoxin and/or Ochratoxin as a hazard and whether it controlled anywhere before? For the neutralization of these mycotoxins (proteins) somewhat higher temperature will be required(for denaturation), could that be the intent of setting this temperature range(?) Or is it because of the sensory value addition?

ochratoxin considered as hazard at bulk storage as OPRP before. shall we considered it as hazard in roasting as CCP? there are color range spesification for each roasted coffee product. but is it okay if decided minimum 200 degree celcius and minimum 5 minute as control limit at roasting process? because there are light, medium, and dark roasting process that we do.

Hi afdilazn,
Just some thoughts came into my mind.
Did your team have considered aflatoxin and/or Ochratoxin as a hazard and whether it controlled anywhere before? For the neutralization of these mycotoxins (proteins) somewhat higher temperature will be required(for denaturation), could that be the intent of setting this temperature range(?) Or is it because of the sensory value addition?

critical limit i mean

ochratoxin considered as hazard at bulk storage as OPRP before. shall we considered it as hazard in roasting as CCP? there are color range spesification for each roasted coffee product. but is it okay if decided minimum 200 degree celcius and minimum 5 minute as control limit at roasting process? because there are light, medium, and dark roasting process that we do.

is it okay if my company (coffee roasting manufacturer) determined CL of roasting with minimum 200 degree celcius and minimum 5 minute? and the roasting is CCP because E coli? my FSTL knows E coli can be reduced even with lower temprature of roasting. but i still didnt get it if only the source is from the workers like its not that CCP because the company is implementationing GMP and SSOP. after did verification flow process there are light, medium, and dark roast. i suggested my FSTL to mention the temperature and times range of each roasting's type in HACCP plan doc. i still haven't got references about its regulation. i need your point of view

 

There seems to be some confusion.

Generic E.coli is not a pathogen.

 

If you mean pathogenic E.coli, you need to justify -

 

(a) that pathogenic E.coli is a significant hazard (is it ?)

(b) if the answer to (a) is yes thereby generating a haccp CCP, the roasting process needs a CL such that any Regulationary xD reduction is attained (if non-existent should consult the literature).

 

Note- 

(i) If a mixture of significant pathogens exists, a typical objective would be to select the most heat resistant.

(ii) The roasting process may itself inevitably require a temperature in excess of haccp minimum CL (analogous to baking process?).

what makes me against that hazard is because the team said the source of E coli is contamination from the worker. if the worker does sanitation himself and personal hygiene everytime their input green beans into roaster, it wouldn't be a significant hazard, right? and we even do e coli test for roasted coffee once in a year. the result for consecutive 3 years is < 3 APM/g and of course we didn't do test for the typical one

There seems to be some confusion.
Generic E.coli is not a pathogen.

If you mean pathogenic E.coli, you need to justify -

(a) that pathogenic E.coli is a significant hazard (is it ?)
(b) if the answer to (a) is yes thereby generating a haccp CCP, the roasting process needs a CL such that any Regulationary xD reduction is attained (if non-existent should consult the literature).

Note-
(i) If a mixture of significant pathogens exists, a typical objective would be to select the most heat resistant.
(ii) The roasting process may itself inevitably require a temperature in excess of haccp minimum CL (analogous to baking process?).

what makes me against that hazard is because the team said the source of E coli is contamination from the worker. if the worker does sanitation himself and personal hygiene everytime their input green beans into roaster, it wouldn't be a significant hazard, right? and we even do e coli test for roasted coffee once in a year. the result for consecutive 3 years is < 3 APM/g and of course we didn't do test for the typical one

 

 

Hi afdizn,

 

In a typical haccp system, verified  Prerequisite programs within GMP should enable the assumption of minimal  likelihood of microbial hazards from facility environment/personnel..

 

Coffee not my area but I anticipate that roasting "eliminates"  microbial pathogens primarily associated with the raw material.

we do handswab test, swab test for the personel's uniform, and the equipment once in a year and the results are lower than acceptable level even 0 cfu/cm2 for handswab test and swab test forpersonel's uniform

Hi afdizn,

In a typical haccp system, verified Prerequisite programs within GMP should enable the assumption of minimal likelihood of microbial hazards from facility environment/personnel..

Coffee not my area but I anticipate that roasting "eliminates" microbial pathogens primarily associated with the raw material.

Hi afdizn,

 

What is the FSTL's justification for regarding (presumably pathogenic) E.coli from workers as a significant hazard ?

 

Having done a quick look on IT regarding coffee roasting there is clearly a lot of existing haccp/CCP related "argumentation". Particularly related to use of end product. For example -

 

https://www.royalnyl...ing-and-brewing

https://www.johnbass...-roasting-a-ccp

 

There are also 2 extended threads on this forum with coffee/haccp info -

 

https://www.ifsqn.co...omes-re-coffee/

https://www.ifsqn.co...harpc-and-fsvp/

 

Based on above, in addition to the general comments in previous Posts, answers to yr specific queries may relate to process details, consumer location, end product use, etc.

the justification is because no one controlled when personnel input green beans (hand washed or not) and that activity barely monitored by head of production

Hi afdizn,

What is the FSTL's justification for regarding (presumably pathogenic) E.coli from workers as a significant hazard ?

Having done a quick look on IT regarding coffee roasting there is clearly a lot of existing haccp/CCP related "argumentation". Particularly related to use of end product. For example -

https://www.royalnyl...ing-and-brewing
https://www.johnbass...-roasting-a-ccp

There are also 2 extended threads on this forum with coffee/haccp info -

https://www.ifsqn.co...omes-re-coffee/
https://www.ifsqn.co...harpc-and-fsvp/

Based on above, in addition to the general comments in previous Posts, answers to yr specific queries may relate to process details, consumer location, end product use, etc.

the justification is because no one controlled when personnel input green beans (hand washed or not) and that activity barely monitored by head of production

 

 

Hi afdlzn,

 

Thks response.

 

It's true that early versions of haccp (ca 1990) did associate hygiene defects with CCPs. The result was often an Encyclopedia of CCPs.

 

However Codex, and particularly NACMCF,  later formalised the (preliminary) use of Prerequisite programs for achieving satisfactory Sanitation, eg - 

 

https://www.fda.gov/...06801.htm#app-a

 

Caveat

 

haccp is "subjective".

 

You can never convince all of the people, all of the time !

 

Despite the above explanation you can still find published documentation that handwashing is a CCP, eg -

 

Malaysia,2012 - Pre-Requisite Programs (PRP) & Critical Control Points (CCP).pdf   314.07KB   62 downloads

 

And, if one includes iso22000 in the discussion, there are numerous claims in the Literature that handwashing is an OPRP. 

 

Although there seem to be fewer documents regarding associated Critical/Action Limits and Validation. :smile:

the bacteria that possible from personnel is s aureus, isnt it? i think e coli as hazard if personnel take a dumb and didn't do sanitation before input green beans. are there reference of growth of s aureus and e coli? because i haven't find it. from what i know both microbes can be killed at temperatures well bellow normal roasting temps

Hi afdlzn,

Thks response.

It's true that early versions of haccp (ca 1990) did associate hygiene defects with CCPs. The result was often an Encyclopedia of CCPs.

However Codex, and particularly NACMCF, later formalised the (preliminary) use of Prerequisite programs for achieving satisfactory Sanitation, eg -

https://www.fda.gov/...06801.htm#app-a

Caveat

haccp is "subjective".

You can never convince all of the people, all of the time !

Despite the above explanation you can still find published documentation that handwashing is a CCP, eg -

Malaysia,2012 - Pre-Requisite Programs (PRP) & Critical Control Points (CCP).pdf

And, if one includes iso22000 in the discussion, there are numerous claims in the Literature that handwashing is an OPRP.

Although there seem to be fewer documents regarding associated Critical/Action Limits and Validation. :smile:

the result test of e coli is < 3 MPN/g seems like it eliminated by roasting. but there are no regulation about e coli in whole beans coffee or ground coffee. then what i should refer to?

generic E.coli is not a pathogen. Should be eliminated by roasting.

S.aureus should also be eliminated but if it had been present at elevated levels might have produced a heat-resistant toxin.

the result test of e coli is < 3 MPN/g seems like it eliminated by roasting. but there are no regulation about e coli in whole beans coffee or ground coffee. then what i should refer to?

 

 

In practice, if no regulatory requirements, the first step is usually to search the literature for similar processes / corresponding specifications / related limits. I predict a guideline will exist. For example via the references in these links -

 

http://www.ifsqn.com...us/#entry127998

http://www.ifsqn.com...ds/#entry127333

 

(For example see ref 3b, Table 4)

thanks for the links, Charles. i think cacao powder has the similar process with ground coffee? and the regulatory requirement of e coli in cocoa powder is < 3 MPN/g same with the latest result of the ground coffee product

In practice, if no regulatory requirements, the first step is usually to search the literature for similar processes / corresponding specifications / related limits. I predict a guideline will exist. For example via the references in these links -

http://www.ifsqn.com...us/#entry127998
http://www.ifsqn.com...ds/#entry127333

(For example see ref 3b, Table 4)