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Mixing of spices, adulteration?


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#1 The Food Scientist

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Posted 16 July 2019 - 05:22 PM

Hello members!

 

So if there is a specific spice that contains a higher than allowable level of Lead, let's say Cinnamon powder.

 

It was sent to a lab and tested and appeared to be adulterated having more than allowable lead levels. So one of our top managers said this: what if we take this cinnamon and blend it with other cinnamons that have acceptable amounts of lead? Is it still violating regulations? (Because his idea is that when you test this new mix, you'd have acceptable levels). My opinion is that that is still considered adulteration, I may be wrong though. Anyone can perhaps share their expertise and knowledge on this subject? And even better reference any FDA/USDA papers that direct me on this? Thank you!


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#2 atifengineer2008

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Posted 16 July 2019 - 06:25 PM

well,in my opnion,you can not Mix.  As fist of all i have to know that what sample size you are taking for Test.when you mix the lot then what should be the sample size for test.

Other thing is that how you are using this mix material,at what quantity and how you ensure that this mix quantity have the same anount of lead that you have allowable limit.Many questions can be raised on this.



#3 majoy

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Posted 16 July 2019 - 06:38 PM

ohhh wow, this person is genius! I'm hoping he's not part of your QA team.

 

Imagine, having a batch with high amount of lead, and then mixing  it with another batch to make the distribution of lead acceptable or within standards? lmao.

 

Are you manufacturing this product? or this came from a supplier?

 

Honestly, If this is from a supplier, i will just go back to the supplier and send them back the batch and let them deal with it. Why do i have to burden myself of potential issues coming from this material.

 

IMO the fact that your company already knows that this batch has high amount of lead, then this is adulteration and anything to hide this will cause so much issue to you and your company in the end.


"Whatever you do, do it well..." - Walt Disney


#4 The Food Scientist

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Posted 16 July 2019 - 06:53 PM

ohhh wow, this person is genius! I'm hoping he's not part of your QA team.

 

Imagine, having a batch with high amount of lead, and then mixing  it with another batch to make the distribution of lead acceptable or within standards? lmao.

 

Are you manufacturing this product? or this came from a supplier?

 

Honestly, If this is from a supplier, i will just go back to the supplier and send them back the batch and let them deal with it. Why do i have to burden myself of potential issues coming from this material.

 

IMO the fact that your company already knows that this batch has high amount of lead, then this is adulteration and anything to hide this will cause so much issue to you and your company in the end.

 

Well that person overlooks QA.... even more sad. lol thanks for sharing a laugh with me.

 

No we're not, we are buying it.

 

So here's what happened:

 

We did go through a recall over the lead issue but it was another supplier, so I went and had all our suppliers test for lead and found another one.  So thats when this "top" manager had his share of thoughts. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#5 SQFconsultant

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Posted 17 July 2019 - 03:29 AM

Nothing like having to work with someone that thinks its ok to cover things up!!!

Why didn't management simply return the batch or contact the supplier to remedy?

Managers like this get their faces on wanted posters at the post office.


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#6 Charles.C

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Posted 17 July 2019 - 08:44 AM

Hello members!

 

So if there is a specific spice that contains a higher than allowable level of Lead, let's say Cinnamon powder.

 

It was sent to a lab and tested and appeared to be adulterated having more than allowable lead levels. So one of our top managers said this: what if we take this cinnamon and blend it with other cinnamons that have acceptable amounts of lead? Is it still violating regulations? (Because his idea is that when you test this new mix, you'd have acceptable levels). My opinion is that that is still considered adulteration, I may be wrong though. Anyone can perhaps share their expertise and knowledge on this subject? And even better reference any FDA/USDA papers that direct me on this? Thank you!

 

Hi FS,

 

To answer yr specific query -
 

 

If a food contains a poisonous substance in excess of a tolerance, regulatory limit, or action level, mixing it with "clean" food to reduce the level of contamination is not allowed. The deliberate mixing of adulterated food with good food renders the finished product adulterated

 

http://vikaspedia.in...on/adulteration

 

 

Mixing techniques are used in other fields, eg mineral ore processing, however a difficulty is that the procedure necessitates the assumption that a  target characteristic is uniformly distributed throughout a lot. This is typically optimistic unless the product is  a well-mixed, finely ground particulate..

 

IIRC it's also used to adjust the physical properties of some bulk liquid food items.


Kind Regards,

 

Charles.C


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#7 pHruit

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Posted 17 July 2019 - 11:04 AM

I presume this is being proposed for the local US market only?
If supplied internationally then possibly worth noting that it's outright prohibited for the EU too - from Article 3 of Regulation (EC) 1881/2006:

1. Foodstuffs not complying with the maximum levels (of contaminants - e.g. lead, mercury etc) set out in the Annex shall not be used as food ingredients.

2. Foodstuffs complying with the maximum levels set out in the Annex shall not be mixed with foodstuffs which exceed these maximum levels.

 



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#8 The Food Scientist

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Posted 17 July 2019 - 12:31 PM

Nothing like having to work with someone that thinks its ok to cover things up!!!

Why didn't management simply return the batch or contact the supplier to remedy?

Managers like this get their faces on wanted posters at the post office.

 

Luckily I was able to work with our purchasing manager and we did contact the supplier and tell them about it. But this one manager just suggested that what if we mix....  :roflmao:


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#9 The Food Scientist

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Posted 17 July 2019 - 12:32 PM

I presume this is being proposed for the local US market only?
If supplied internationally then possibly worth noting that it's outright prohibited for the EU too - from Article 3 of Regulation (EC) 1881/2006:

1. Foodstuffs not complying with the maximum levels (of contaminants - e.g. lead, mercury etc) set out in the Annex shall not be used as food ingredients.

2. Foodstuffs complying with the maximum levels set out in the Annex shall not be mixed with foodstuffs which exceed these maximum levels.

 

yes only US


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#10 The Food Scientist

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Posted 18 July 2019 - 08:30 PM

I have another question and figured I'd add it here instead of opening a new topic:

 

Can someone lead me to a source that can help me to find out in which spices shall I be testing lead?

 

We buy almost every spice you can think of. Now do we also have to test for seeds? For example flaxseeds? Sesame, Chamomile flowers...etc Also one supplier said they do testing on powders not seeds..Is there a source? Because I need to request some paperwork from a supplier for lead and tell him what products we shall be looking for? Thanks!


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#11 bensmith007

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Posted 18 July 2019 - 09:24 PM

I work for a spice supplier and we are moving to require an at minimum annual test for all herbs and spices that we purchase for big 4 heavy metals, mycotoxins where recommended, and pesticide residues according to EPA MRLs. Going back a few years, these items were not really on the horizon for spice companies but times are changing rapidly and this is really something you should be requiring from your supplier now to weed out those who are still stuck in the past and ignoring these issues- the spice supply chain can be extremely convoluted and there is a lot of inferior product out there so ensure your supplier has a handle on these issues.

 

Lead is often associated with rhizomes (turmeric and ginger) as these grow underground where heavy metals will be found in soil, but we see (low level) heavy metals in most spices to be honest. We subscribe to HorizonScan for any spice safety alerts around the world- looking at the Q2 report there were no heavy metal issues raised, problems were with Salmonella, undeclared allergens, adulteration, pesticide/herbicide residues, and mycotoxins mainly. As we have a presence in the spice growing regions, we can exert more control over the supply chain and work with farmers or co-ops to improve good agricultural practice, and this really is pretty key to controlling these issues well as it is often this first step where problems occur, e.g. overuse of pesticides through lack of knowledge and training. In my few years here we have not yet had a problem with heavy metals and we buy many tons of herbs and spices.

 

The representative industry body in the US is the American Spice Trade Association, ASTAspice.org and they have lots of information on the trade, but I shouldn't really share any documents here as they are for paid members- if your supplier is a member of ASTA maybe they are able to share directly with you.

 

DM me if there is anything else I can help you with (or recommend you a new spice supplier!)

 

Ben


Edited by bensmith007, 18 July 2019 - 09:24 PM.


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#12 Charles.C

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Posted 20 July 2019 - 12:58 AM

Seems to be a ton of data on internet, eg -

 

https://www.inspecti...0/1430828028356

 

also long Pb list in this 2012, NZ, document -

 

Attached File  chemical-contaminants-imported-dried-spices.pdf   489.29KB   7 downloads

 

and yes, there are a few "nasties"

 

PS - some of ASTA stuff is free to download on internet. Their (perhaps slightly truncated) haccp manual is variously attached on this Forum.

 

https://www.astaspice.org/food-safety/


Kind Regards,

 

Charles.C


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