7 replies to this topic

[Marcos77]

Hello all,

 

I am working on building my first food safety plan, so beware of the newbie!  I have searched the forum pretty well so hopefully I am not repeating any questions already asked.

 

I work for a very small coffee roaster whose only product is organic, non-flavored, roasted coffee beans.  I am having some trouble finding any data or research showing what allergens may be mixed with the raw green beans.  I have process controls for foreign materials and environmental pathogens, but I am not sure what I should be targeting when it comes to allergens.  Nuts, soy, etc?  Where could I find some info on this?

 

I know a lot of junk can come in with raw green beans, so I assume there is some risk of unintentional allergen contamination in the coffee we receive.  Does anyone have any recommendations as to what kind of controls I can put in place when our only product doesn't contain any allergens as an ingredient?

 

Also, the FSVP guidance has given our importers a bit of a free pass when it comes to controlling hazards for raw agricultural commodities, so there doesn't seem to be much I can ask from our suppliers.

 

Thanks all for any help, and bear with me if I ask any dumb questions.  Still learning!

[SafetyLine]

Hello,

 

In my opinion and experience, if you don't use any allergen in your plant, isn't a risk for you process. However you need to declared this situation in your food safety plan.
Are you obtain your green beans by yourself or by a supplier? If is by yourself, you need to do a risk assessment in your fields and nearby fields , but if you obtain by a supplier your raw material, ask him for a risk assessment focus on allergen hazard, that need to include a allergen procedure and allergen sanitation validation study.

I don't have too much experience in agricultural plant, my strength is the frozen food processing industries. I hope this information be useful for you! 

 

P.S. Sorry for my English redaction, I'm still learning.

 

Best Regards

[The Food Scientist]

Not sure I understand much but here are my two cents:

 

 

 

I work for a very small coffee roaster whose only product is organic, non-flavored, roasted coffee beans.  I am having some trouble finding any data or research showing what allergens may be mixed with the raw green beans.  I have process controls for foreign materials and environmental pathogens, but I am not sure what I should be targeting when it comes to allergens.  Nuts, soy, etc?  Where could I find some info on this?

 

 

 

So you are asking what allergens you can add to your coffee beans? it's up to you. BUT you MUST declare it on the specification sheet and label for your customers and you MUST have an Allergen control plan in place.

 

 

 

 

I know a lot of junk can come in with raw green beans, so I assume there is some risk of unintentional allergen contamination in the coffee we receive.  Does anyone have any recommendations as to what kind of controls I can put in place when our only product doesn't contain any allergens as an ingredient?

 

 

Yes there is a risk and you must ask your supplier for that info or you can do your own allergen tests by sending to a third party lab to test any protein residue from any targeted allergens. 

 

I hope I quite understood and somehow answered your questions? :) 

[AC2018]

Look into coffee roasting as a 'kill step' to denature or destroy allergens as allergen control. Maybe that could be a plan B if you can't find a way to control the potential of unintentional allergen contamination. Also, maybe try to find a lab that can test each of the major 8 allergens to see if there is any present on the green beans. And if there is then you can work on figuring out how to control it or also have testing done after they are roasted. 

[Marcos77]

Thanks everyone, this has been helpful!  

 

We receive our raw green beans from importers that often don't even touch the product, just handle the paperwork from the farm to our facility.  When I ask them for any info on controlling hazards, they say that the hazard has to be controlled by us.  So not much help from our importers.

 

I am not looking to add allergens to our product.  I am wondering more how to write a formal allergen control point (fsma required?) when we don't have any known allergens.  If there are any known allergens that are unintentionally introduced during the farming process, I can't seem to find any information supporting it. 

 

Having our product tested sounds like a good way to gather our own historical data.  I guess I don't see necessarily see the hazard in our product, but I believe FSMA requires us to have an Allergen Control Point, so this may be the path we will have to take to justify having a control point.

[twingo]

Hi Mark77,

 

A couple points for you:

• Your importers should be compliant with the Foreign Supplier Verification Program rules.  Part of the FSVP is documenting a hazard analysis, which includes allergens.  You may want to clarify with your suppliers about their assessments for the presence of a hazard, not just whether or not they are controlling it.
• If you are not bringing allergens into your plant, nor including them as a part of your formulation, then your allergen control program is going to be preventative.  I.e. focusing on supplier documentation of presence of a hazard or risk analysis for unintentional introduction of a hazard, supplier approval programs requirements including suppliers have an allergen plan in pace (even if they don't handle allergens, just like you), and procedures for what you as an organization will do in the event that your process or formula's changes and allergens were to be on-site (i.e. label, quarantine, sanitize and verify sanitation).
• Allergen cross-contact and allergen mislabelling are some of the leading causes of recall for FDA regulated CPG.  Their intention with the rules is to ensure food processors have thought through the hazard and would know how to minimize the risks associated with it.  So have a good plan for how they would be handled, ensure any new suppliers or products get reviewed for allergen risk, & include label review processes and you will be compliant with FSMAs allergen preventive controls.  You will not necessarily always identify an allergen hazard during a hazard analysis, but it is still a good idea to have a preventive allergen control plan in place that includes basic processes for allergen labelling, quarantine, sanitization, verification sanitation, and employee training of the Big 8.

[kettlecorn]

 

Hi Mark77,

 

A couple points for you:

• Your importers should be compliant with the Foreign Supplier Verification Program rules.  Part of the FSVP is documenting a hazard analysis, which includes allergens.  You may want to clarify with your suppliers about their assessments for the presence of a hazard, not just whether or not they are controlling it.
• If you are not bringing allergens into your plant, nor including them as a part of your formulation, then your allergen control program is going to be preventative.  I.e. focusing on supplier documentation of presence of a hazard or risk analysis for unintentional introduction of a hazard, supplier approval programs requirements including suppliers have an allergen plan in pace (even if they don't handle allergens, just like you), and procedures for what you as an organization will do in the event that your process or formula's changes and allergens were to be on-site (i.e. label, quarantine, sanitize and verify sanitation).
• Allergen cross-contact and allergen mislabelling are some of the leading causes of recall for FDA regulated CPG.  Their intention with the rules is to ensure food processors have thought through the hazard and would know how to minimize the risks associated with it.  So have a good plan for how they would be handled, ensure any new suppliers or products get reviewed for allergen risk, & include label review processes and you will be compliant with FSMAs allergen preventive controls.  You will not necessarily always identify an allergen ust to follow up on twingo said on the FSVP, which your importers absolutely should be complying with, also be aware that the FDA has strict guidelines on insect adulteration and mycotoxins. You'll want to make sure your importer is accounting for this in the FSVP too. When you say "I know a lot of junk can come in with raw green beans" your food safety plan needs to : hazard during a hazard analysis, but it is still a good idea to have a preventive allergen control plan in place that includes basic processes for allergen labelling, quarantine, sanitization, verification sanitation, and employee training of the Big 8

 

Just to follow up on twingo's helpful comments on the FSVP, which your importers absolutely should be complying with, also be aware that the FDA has strict guidelines on insect adulteration and mycotoxins in coffee beans. You'll want to make sure your importer is accounting for this in the FSVP too. You say "I know a lot of junk can come in with raw green beans," and the FSVP (and by extension your food safety plan) needs to risk assess all of that junk too: 

 

https://www.fda.gov/...erage-materials

 

https://www.fda.gov/...on-insects-mold

[Marcos77]

 

Hi Mark77,

 

A couple points for you:

• Your importers should be compliant with the Foreign Supplier Verification Program rules.  Part of the FSVP is documenting a hazard analysis, which includes allergens.  You may want to clarify with your suppliers about their assessments for the presence of a hazard, not just whether or not they are controlling it.
• If you are not bringing allergens into your plant, nor including them as a part of your formulation, then your allergen control program is going to be preventative.  I.e. focusing on supplier documentation of presence of a hazard or risk analysis for unintentional introduction of a hazard, supplier approval programs requirements including suppliers have an allergen plan in pace (even if they don't handle allergens, just like you), and procedures for what you as an organization will do in the event that your process or formula's changes and allergens were to be on-site (i.e. label, quarantine, sanitize and verify sanitation).
• Allergen cross-contact and allergen mislabelling are some of the leading causes of recall for FDA regulated CPG.  Their intention with the rules is to ensure food processors have thought through the hazard and would know how to minimize the risks associated with it.  So have a good plan for how they would be handled, ensure any new suppliers or products get reviewed for allergen risk, & include label review processes and you will be compliant with FSMAs allergen preventive controls.  You will not necessarily always identify an allergen hazard during a hazard analysis, but it is still a good idea to have a preventive allergen control plan in place that includes basic processes for allergen labelling, quarantine, sanitization, verification sanitation, and employee training of the Big 8.

 

 

This is really great information. Thank you for clarifying this for me.  For some reason I thought I had to identify an allergen for during my hazard analysis.  I will definitely be pressing our suppliers for more information on their FSVP compliance.  I already have the bones of an Allergen control program that involves employee training because of lunchroom cross-contamination.  I will be working to build up this program now as well.

 

 

Just to follow up on twingo's helpful comments on the FSVP, which your importers absolutely should be complying with, also be aware that the FDA has strict guidelines on insect adulteration and mycotoxins in coffee beans. You'll want to make sure your importer is accounting for this in the FSVP too. You say "I know a lot of junk can come in with raw green beans," and the FSVP (and by extension your food safety plan) needs to risk assess all of that junk too: 

 

https://www.fda.gov/...erage-materials

 

https://www.fda.gov/...on-insects-mold

 

Thanks for these links, they pretty much answer most of my questions right now!

 

Just to follow up though, I think I see where my confusion with FSVP was. In the past I have received from one of our suppliers an "Importer Disclosure Statement" that refers to the following FDA guidance document:

 

https://www.fda.gov/...110302/download

 

I believe I may have been misunderstanding this document when it states "The preventive control requirements, including the Supply-chain program provisions, do not apply to facilities that are solely engaged in the storage of non-produce RACs intended for further distribution or processing."

 

As I read it, they still need to follow the FSVP rules, just that they don't have to have a preventive control to control it.  This makes so much more sense now.

 

 

Thanks again for the help everyone.  Things are starting to come together now.