Does anyone have experience with the FSMA requirement for written notification of uncontrolled hazards (21 CFR 117.136)? Our R&D department is working on a new product, organic hemp hearts, but the supplier's spec sheet for the material explicitly discloses at the bottom that it is not processed to control microbial pathogens. How can we proceed with a product that is not processed to control Samonella, which is an identified hazard for this product? Is it sufficient to label them as "raw" hemp hearts if R&D does not wish to steam pasteurize?
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