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HACCP for loose leaf tea - all advice welcome

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JillLovesTea

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Posted 01 April 2020 - 04:03 PM

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! 

 

 



pHruit

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Posted 01 April 2020 - 05:21 PM

Welcome to the forum :welcome:

I've never worked with tea, but I found this from one of the European industry associations that might be useful as a reference for you: https://www.thie-onl...s__Website_.pdf

 

In terms of your other specific questions:
Glass is a potential hazard. If I make myself a cup of tea in a glass mug and I chip/break it, then its (a) my problem, and (b) something I'm hopefully going to notice that I've done. If I buy a loose-leaf tea with bits of glass in it I've no way of knowing that until I start drinking it ;)

This is the most recent thread that I can recall on glass control and may contain some useful ideas, but if you have a search of the forum then there will certainly be more: https://www.ifsqn.co...lass-packaging/

 

In terms of a microbiological CCP, I suspect that there probably isn't one. For your HACCP analysis you're looking at potential micro/chemical/physical hazards (and possibly others for some certification standards), but for some products/processes it's entirely legitimate to conclude that there isn't one. As you aren't undertaking a kill step, or any other activity that reduces microbiological hazards (at least, I expect you're not?) then your conclusion may be that this is actually a prerequisite - i.e. you're ensuring you're buying product with the right microbiological specification, as you aren't able to do anything to correct it if it's wrong. This is therefore likely to be managed through your supplier approval process and your suppliers test results in the form of CoAs, possibly augmented with some of your own monitoring to verify their results if your assessment of the risk indicates that this is necessary.



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JillLovesTea

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Posted 01 April 2020 - 07:02 PM

Thank you, thank you, thank you!! I have that .PDF you linked saved in my bookmarks already actually. It's very helpful. :) 

 

 

 

Glass is a potential hazard. If I make myself a cup of tea in a glass mug and I chip/break it, then its (a) my problem, and (b) something I'm hopefully going to notice that I've done. If I buy a loose-leaf tea with bits of glass in it I've no way of knowing that until I start drinking it ;)

I totally agree! I wouldn't want glass or rocks or chunks of wood etc in my tea either. It's a matter of quality, for sure, and we have procedures in place to monitor that. BUT, is there an inherent risk to people if they are in there? We aren't chewing or swallowing the tea leaves.   :huh: Would this hazard not be dealt with the same way as the microbial hazard --- as a pre-requisite in the form of a thorough glass policy as mentioned in the thread you linked? Your response there was pretty clear on what features such a glass policy would have. 



pHruit

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Posted 01 April 2020 - 07:19 PM

Thank you, thank you, thank you!! I have that .PDF you linked saved in my bookmarks already actually. It's very helpful. :) 

 

 

I totally agree! I wouldn't want glass or rocks or chunks of wood etc in my tea either. It's a matter of quality, for sure, and we have procedures in place to monitor that. BUT, is there an inherent risk to people if they are in there? We aren't chewing or swallowing the tea leaves.   :huh: Would this hazard not be dealt with the same way as the microbial hazard --- as a pre-requisite in the form of a thorough glass policy as mentioned in the thread you linked? Your response there was pretty clear on what features such a glass policy would have. 

Sorry, yes, I should have been clearer with my phrasing - I'd address the glass risk via a control program that for HACCP purposes would be considered a prerequisite.



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JillLovesTea

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Posted 01 April 2020 - 07:35 PM

You're the best - thanks so much! 



thisusernameisnottaken

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Posted 13 May 2021 - 09:59 PM

Hello -

Welcome! I am a fellow compliance manager from a bagged tea company - don't see to many tea peeps on this forum :)

 

While we don't sell bulk teas our blending process and raw materials are probably similar. We do not have any CCP's identified in our Food Safety/HACCP plan as our PRP's adequately control identified hazards. We do have supply chain PC's though and do a lot of raw material testing to validate suppliers COA. I agree that your food safety rationale being "low risk" is accurate but might I suggest adding evidence of this (we use water activity as our justification) 

 

Validating steep times by certified 3rd party labs is a very important step in determining appropriate steep times for each of our SKU's. This is where product labeling comes into play, especially since we are technically relying on consumer to employ the kill step by following labelling instructions. These steep times vary from SKU to SKU based on blend of tea and inherent raw material attributes. Good Luck. 

 

Have a tea-riffic day!



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