5 replies to this topic

[Pete_Rev]

Hi all,

 

We are a large apple juice manufacturer and have a customer that wants to purchase unpasteurised single strength (i.e. not-from-concentrate) apple juice from us. The customer will ferment the juice into cider. pH of the juice is <4.2. We routinely make pasteurised single strength juice.

 

Process will be:

1. Apple washing and grading

2. Milling

3. Pressing

4. Holding in non temperature controlled tank

5. Filling into customer supplied road tanker

 

We are struggling with how to validate the holding time (or "shelf life") of the juice before it is collected by the customer's supplied tanker. We have FSSC22000.

 

At the holding stage (step 4) we have said the customer must pick up within 4 hours. This is fairly arbitrary. We have assessed this from a quality point of view, and can confirm there will be colour changes and no physical signs of fermentation within 4 hours. We have also micro tested unpasteurised juice (APC, Y&M and coliforms) and unsurprisingly the counts are too numerous to count. 

 

From a food safety POV we could send for pathogen testing for our target organisms (E.coli and Salmonella) but we won't be able to replicate the holding time due to travel time to the external lab. Even if we do get pathogens found, we will not be applying a control point as our customer has requested no heat treatment.

 

Second part is if we know our customer is going to further process, are we still required to validate the process? It is unpasteursied so inherently a hazardous product.

 

any advice much appreciated!

[Charles.C]

Hi Pete-Rev,

 

Just as a side-comment, I would guess yr last query may be a NZ Regulatory issue within your FSMS. (generally, IIRC,  iso22000 includes an option in its hazard analysis requirements when a (validatable) further (onward) process control measure may "handle" a hazard identified at the first stage).

 

Just as a possible typo in OP, did you mean "no" colour changes ?

 

IIRC, commercialised, unpasteurised, fruit juices in USA require a warning label/disclaimer to be attached.

[Pete_Rev]

Hi Charles, 

 

Interesting reply. This point was noted during an FSSC22000 audit. However it was also noted during a subsequent NZ regulatory audit.

 

Regarding ISO22000, I wonder if you are referring to 7.4.2.2 which says:

"When identifying hazards, consideration shall be given to:

a) the steps preceding and following the operation,

b) the process equipment, utilities/services and surroundings, and

c) the preceding and following links in the food chain"

 

Point C seems to infer that if a hazard is controlled in the following link in the food chain (i.e. the direct customer in our scenario) then that may be acceptable?

 

To clarify re colour changes, the colour of the juice will change (darken) over time.

 

Regarding your final point, in NZ the requirement is to produce food that is "safe and suitable" (our regulations are much less prescriptive). This is of course up to the operator to prove, and in this case we have clearly stated to the customer that any unpasteurised juice is not fit for human consumption without further processing.

[Charles.C]

Hi Charles, 

 

Interesting reply. This point was noted during an FSSC22000 audit. However it was also noted during a subsequent NZ regulatory audit.

 

Regarding ISO22000, I wonder if you are referring to 7.4.2.2 which says:

"When identifying hazards, consideration shall be given to:

a) the steps preceding and following the operation,

b) the process equipment, utilities/services and surroundings, and

c) the preceding and following links in the food chain"

 

Point C seems to infer that if a hazard is controlled in the following link in the food chain (i.e. the direct customer in our scenario) then that may be acceptable?

 

To clarify re colour changes, the colour of the juice will change (darken) over time.

 

Regarding your final point, in NZ the requirement is to produce food that is "safe and suitable" (our regulations are much less prescriptive). This is of course up to the operator to prove, and in this case we have clearly stated to the customer that any unpasteurised juice is not fit for human consumption without further processing.

 

Hi Pete,

 

Thks clarification. So no typo. Good to know.

 

Yes, I was remembering point (c). the latest version has -

 

When identifying hazards, the organization shall consider:
a)  the stages preceding and following in the food chain;
b)  all steps in the flow diagram;
c)  the process equipment, utilities/services, process environment and persons.

 

 

Some traditional haccp texts clearly state that the likelihood of a hazard occurring should be referenced to the (literal)  point of consumption, eg will include/follow the consumer's  cooking of a raw product and thereby auto-rendering a potential hazard as non-significant.  ISO22000(2018) now includes a definition of a "significant hazard" but afaik leaves the specific reference point unstated. I choose to interpret it for myself.

 

The well-known Coca-Cola CCP/OPRP decision tree handles the above situation in an equivalent way but textually slightly different. See attachment/box No.2.

 

 COCA COLA MICHIGAN STATE CCP-OPRP tree.pdf   96.37KB   26 downloads

 

A 3 stage situation can occur when companies process/ship intermediate raw products for further processing to yield a retail product which will subsequently be labelled as "must be cooked".

 

The above examples are auditorially sort of self-evident validations however in yr case I'm less clear how you will validate any onward control. Perhaps documentarily ?.

 

I would have guessed any (safety-related) validation of holding time would be linked to controlling (if necessary) the occurrence of a target pathogen exceeding a level which is removable  by next stage. Spoilage factors like APC are not haccp-relevant albeit maybe sensitive Quality factors.

[pHruit]

I've seen this post rather late, so you may have already resolved your issue.
Nonetheless this may be a useful reference for you to add, in terms of the position that the subsequent process undertaken by the customer will address potential microbiological hazards: https://jfoodprotect...028X-59.12.1256

They should (hopefully) also have some validation around their own process that they may be able to share with you?

 

Do you have any chilling facilities on site?

This will also help. Aside from HACCP considerations, based on experience with unpasteurised juices the real limiting factor on your shelf life is almost certainly going to be spoilage, and if you can pass through cooling stage before putting it into a tank (ideally insulated) to hold for your customer to load from then this will help.

FWIW we used to buy tankers of unpasteurised apple juice with a total life of 48h from pressing.

 

Are you able to provide any numbers around the TNTC figures you're seeing for the micro?
Just curious but presume you've tried plating at different dilutions to see if you are able to enumerate.

IIRC we were buying a spec of TVC <2.5x10⁵, Y<2.5x10⁵ and M<2.5x10⁴.

There may of course be scope to improve the micro figures with changes to washing processes etc, but appreciate this is going to very much be a question of effort vs. reward for what may be a relatively small-scale project. Obviously also potential impact from the source of the fruit (collected from ground vs. direct from tree can have a very large impact), but that can become even more involved...

[Pete_Rev]

Hi pHruit, thanks for your input. Better late than never!

 

Thanks for the article, coincidentally the unpasteurised juice is going to a cider maker that is pitching yeast basically as soon as it is pumped into the fermenter. So we are pretty confident that the pH drop due to fermentation will be controlling any potential pathogens. They are also sterile filtering.

 

We don't have any chilling facilities unfortunately, they juice is sitting at ambient temperatures, which in our part of New Zealand can be up to around 20 degrees at this time of year. 

 

We have sent samples of the unpasteurised juice for E.coli and Salmonella testing and both have come back negative so we are pretty happy with that result. 

 

I don't have the TNTC figures unfortunately, we could possibly enumerate but customer seems happy buying as is for now.