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Seasoning microbiology limits/criteria in the U.S.

spices seasoning microbiology foodsafety APC criteria

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#1 katss

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Posted 07 November 2019 - 02:49 AM

Attached File  Screen Shot 2019-11-06 at 8.49.37 PM.png   142.65KB   5 downloadsHello all,

 

This is in regards to an imported seasoning composed mainly of smoked chili. 

 

The COA came back with >25,000 APC, a consultant suggested to get it tested again to get the exact APC, coming back at 1,700,000. See attached file.

 

Based on my research I see is quite normal to have a high APC on spices/seasonings.

 

It appears FDA do not have any specific microbiological criteria for seasonings or spices. I have found studies and recommendations but no legislation. I am aware that parameters are also agreed between supplier and customer.

 

With this being said, these are my questions: 

 

Have you seen this type of value on a similar product?

 

What is the max suggested APC in the industry?

 

What value should I list on the COA >25,000 or 1,700,000 ?

 

 

Ps: we intend to sell the product to consumers as well wholesale. Ultimately we want to make sure the product is safe to the public.

 

 

Your input is greatly appreciated!

 


Edited by katss, 07 November 2019 - 02:52 AM.


#2 dstout

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Posted 07 November 2019 - 07:38 PM

Does this undergo a kill step? Whats you CCP if not?

 

I would declare >25,000 as there is no need to call out the specific numbers you are getting that are higher than this limit.

 

Perform historical data gathering and see if you can hone in on an average but I'd still maintain the >25,000 on the COA.

These high APC numbers are very common for spices and it would be shocking to see the FDA move to setting limits for indicator organisms.

 

Cheers.



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#3 Charles.C

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Posted 07 November 2019 - 08:47 PM

attachicon.gif Screen Shot 2019-11-06 at 8.49.37 PM.pngHello all,

 

This is in regards to an imported seasoning composed mainly of smoked chili. 

 

The COA came back with >25,000 APC, a consultant suggested to get it tested again to get the exact APC, coming back at 1,700,000. See attached file.

 

Based on my research I see is quite normal to have a high APC on spices/seasonings.

 

It appears FDA do not have any specific microbiological criteria for seasonings or spices. I have found studies and recommendations but no legislation. I am aware that parameters are also agreed between supplier and customer.

 

With this being said, these are my questions: 

 

Have you seen this type of value on a similar product?

 

What is the max suggested APC in the industry?

 

What value should I list on the COA >25,000 or 1,700,000 ?

 

 

Ps: we intend to sell the product to consumers as well wholesale. Ultimately we want to make sure the product is safe to the public.

 

 

Your input is greatly appreciated!

 

Re red ^^^, this result is probably meaningless. it probably means the plates were overloaded with bacteria, ie uncountable.

 

Assuming hot smoked at >= 70degC,  the APC result 1.7M looks extremely high.


Kind Regards,

 

Charles.C


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#4 Hank Major

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Posted 07 November 2019 - 10:11 PM

There is no FDA-imposed APC/TPC limit.  You are expected to have done research and collected data to determine your own limits.  My usual system is to consider TPC an indicator of general cleanliness, but not to assign a Critical Limit to it.

 

The 1,700,000 number is rather high, and suggests that it rained during the smoking process (or before or after).  The 320 mold number is also consistent with excess moisture.  Smoking of chili peppers is still done "artisanally" in some places.  (Replace the word "artisanally" with "outside".)  Chili peppers are very wet and have little inherent ability to prevent microbial growth, so if there is are delays in drying, the bacteria and mold can multiply. 

 

My clients would never accept an open-ended >25,000 APC.  They would demand real numbers, on a third party lab COA, and demand the COA before purchasing.  If the products often went over a million, then they would ask for an aflatoxin test too. 

 

In the case of the stuff you already have, does it smell or taste bad?  If not, it should be okay as a one-time thing.



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#5 katss

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Posted 08 November 2019 - 01:37 AM

Does this undergo a kill step? Whats you CCP if not?

 

I would declare >25,000 as there is no need to call out the specific numbers you are getting that are higher than this limit.

 

Perform historical data gathering and see if you can hone in on an average but I'd still maintain the >25,000 on the COA.

These high APC numbers are very common for spices and it would be shocking to see the FDA move to setting limits for indicator organisms.

 

Cheers.

Does this undergo a kill step? no

Whats you CCP if not? receiving stage, my control measure would be the COA and the Letter of Guarantee.



#6 katss

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Posted 08 November 2019 - 01:39 AM

Re red ^^^, this result is probably meaningless. it probably means the plates were overloaded with bacteria, ie uncountable.

 

Assuming hot smoked at >= 70degC,  the APC result 1.7M looks extremely high.

I just want to make sure I understood correctly, you think the second test result is invalid or wrong? should I have it tested again?



#7 katss

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Posted 08 November 2019 - 01:43 AM

There is no FDA-imposed APC/TPC limit.  You are expected to have done research and collected data to determine your own limits.  My usual system is to consider TPC an indicator of general cleanliness, but not to assign a Critical Limit to it.

 

The 1,700,000 number is rather high, and suggests that it rained during the smoking process (or before or after).  The 320 mold number is also consistent with excess moisture.  Smoking of chili peppers is still done "artisanally" in some places.  (Replace the word "artisanally" with "outside".)  Chili peppers are very wet and have little inherent ability to prevent microbial growth, so if there is are delays in drying, the bacteria and mold can multiply. 

 

My clients would never accept an open-ended >25,000 APC.  They would demand real numbers, on a third party lab COA, and demand the COA before purchasing.  If the products often went over a million, then they would ask for an aflatoxin test too. 

 

In the case of the stuff you already have, does it smell or taste bad?  If not, it should be okay as a one-time thing.

Thanks for your input.

The product it is done "artisanally". 

The product we have does not smell or taste bad. 



#8 dstout

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Posted 05 December 2019 - 06:04 PM

I would just document your due diligence annually and you should be good. i.e. just perform this annually after you have gathered enough data to be able to say hey look every time we test a new lot it's going to have APC off the charts. Are you also testing for any other potentially harmful organism? 



#9 FurFarmandFork

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Posted 05 December 2019 - 08:48 PM

I just want to make sure I understood correctly, you think the second test result is invalid or wrong? should I have it tested again?

 Results like that are due to there being so many colonies on the plate that it was impossible to discriminate and physically count. Your retest would have been done with additional dilutions, which means you have a better estimate of the value, but less precision in the result (e.g. really only within order of magnitude).

 

Before you go about testing again, what information are you expecting to get from the result? Looking at the answers above, it seems like general aerobic organisms are not a helpful safety indicator in your product, hence why you look for (some) pathogens specifically. The NACMCF limits for spices (ready to eat) recommend an APC limit of 10^5/gram. (e.g. 100,000 CFU/g), but if you exceed that limit they recommend "investigate", not reject.

 

If you normally receive product with fewer organisms, then this is an outlier and many of the folks above suggested reasons why (excess moisture, mold spoilage, whatever). If instead you normally receive products with lots of organisms, then this isn't abnormal, and it certainly isn't a safety indicator. If anything you're going to be afraid of off flavors/aromas from spoilage organisms or shorter shelf life for the same reasons.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

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#10 Charles.C

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Posted 06 December 2019 - 01:48 AM

I just want to make sure I understood correctly, you think the second test result is invalid or wrong? should I have it tested again?

 

Hi katss,

 

Sorry for non-response, I missed yr last post(s).

 

Posts 4 / 9 are relevant in respect to typical expectations and micro. accuracy.

 

Smoking not my area of expertise but, just as a generic comment, the basic Quality of many foods is often regarded as becoming "debatable" when the APC approaches 107 cfu/gm (there are some well-known exceptions,,eg fermented foods). Maybe helpful to compare some typical data for smoked chili.

 

APC sampling data often exhibits high variability. It is IMO unrealistic to only submit one sample, especially where decision-making is involved..


Kind Regards,

 

Charles.C






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