Hi guys!
I work for a small tea manufacturer (more on what we do below). In the last month and a half I've been training with him on HACCP and FSMA as a back up to our current "compliance guy" which is great timing as he's recently quit the company. My training has consisted of taking online courses and a LOT of googling/research. The previous "compliance guy" has offered very little guidance and often didn't have answers to my questions. To make matters worse, tea seems to be a pretty big blind spot in the HACCP universe.
What we do.... We "manufacture" loose leaf tea, which is to say we purchase and store tea leaves, flower petals, herbal ingredients and some dried fruit pieces which are mixed together with some organic liquid flavorings and then package it a few different ways. A huge portion of our items are packed by hand, but we do have a handful of big machines that portion the loose leaf tea into tea bags and such. 90% of our business is to other businesses like restaurants and cafes who prepare the tea on site and serve to customers. We have a small retail outlet where we sell the same teas in appropriate quantities for at-home use.
I had initially began our HACCP plan taking to account every possible hazard, but in researching tea's nearest cousin - coffee - I'm noticing that there's some debate about whether tea is considered "low risk" as it's not consumed whole and I now believe I may be overthinking things quite a bit. I'm desperate for a little guidance from those more experienced than myself. Obvious risks in tea mirror those in coffee quite closely with the exception that coffee is typically purchased green and roasted on site (a kill step) where tea is purchased pre-processed (and with COAs, from approved vendors to avoid nasty chemical surprises left over from processing).
We package some teas into glass jars -- is broken glass a hazard? Sure, but no one is eating the tea leaves so even if there is a bit of glass the risk is not any more significant than brewing in a glass mug. Aside from having a thorough glass policy (examples of which I've found on this forum), is there anything else I should do here?
If there is no cooking of our tea on site as in coffee to act as a kill step, what could our CCP for pathogens or mycotoxins look like? I feel like all we can do is prevent these through vendor control, storage practices and clear directions on the package to not consume the tea raw. Is that enough?
All help is appreciated. Thank you, everyone!