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Acidified foods - Dietary supplements

HACCP CCP Acidified foods DietarySupplements Preservatives KillStep

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SafetyP

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Posted 14 April 2022 - 02:13 PM

Hello, 

 

We manufacture and pack dietary supplements. We have been making a specific product for 10+ years. During an audit it was mentioned that this product needed to have a CCP indicated in the HACCP Plan. They also mentioned that it should be listed as an acidified food. See quoted text below. 

 

"This product will need a Process Authority Letter.  Without the presence of preservatives, pathogens could grow and feed on the vitamins.  With preservative present, this establishes a Kill step. "kill step" is incorporating the use of preservatives Sodium Benzoate, Potassium Sorbate, and Sodium Hexametaphosphate as usage concentrations that are operationally viable, and will be effective.  On the PA letter, the Kill step will be identified as "use of preservatives" at concentrations listed.  Note that the product will be on hold until preservative levels are confirmed."

 

We would like to continue without categorizing this product as an acidified food as the pH and water activity doesn't fall into the listed parameters. We also never described the addition of preservatives as a "kill step" in the process. We test all raw materials, water, finish product and stability.  

 

 

Any advice would be greatly appreciated. 

 



Scampi

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Posted 14 April 2022 - 04:06 PM

What is your pH and aw?


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SafetyP

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Posted 14 April 2022 - 05:34 PM

Good afternoon, 

 

pH 3.65 or 3.75

aw .96



Scampi

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Posted 14 April 2022 - 05:51 PM

According to below you ARE acidified and as such you must follow a scheduled process---UNLESS you are not changing the pH and that is naturally where you're product falls.....can you clarify?

 

 

 

b) Acidified foods means low-acid foods to which acid(s) or acid food(s) are added; these foods include, but are not limited to, beans, cucumbers, cabbage, artichokes, cauliflower, puddings, peppers, tropical fruits, and fish, singly or in any combination. They have a water activity (aw) greater than 0.85 and have a finished equilibrium pH of 4.6 or below. These foods may be called, or may purport to be, "pickles" or "pickled ___." Carbonated beverages, jams, jellies, preserves, acid foods (including such foods as standardized and nonstandardized food dressings and condiment sauces) that contain small amounts of low-acid food(s) and have a resultant finished equilibrium pH that does not significantly differ from that of the predominant acid or acid food, and foods that are stored, distributed, and retailed under refrigeration are excluded from the coverage of this part

 

e) Scheduled process means the process selected by a processor as adequate for use under the conditions of manufacture for a food in achieving and maintaining a food that will not permit the growth of microorganisms having public health significance. It includes control of pH and other critical factors equivalent to the process established by a competent processing authority.

 

(1) Acidified foods shall be so manufactured, processed, and packaged that a finished equilibrium pH value of 4.6 or lower is achieved within the time designated in the scheduled process and maintained in all finished foods. Manufacturing shall be in accordance with the scheduled process. Acidified foods shall be thermally processed to an extent that is sufficient to destroy the vegetative cells of microorganisms of public health significance and those of nonhealth significance capable of reproducing in the food under the conditions in which the food is stored, distributed, retailed and held by the user. Permitted preservatives may be used to inhibit reproduction of microorganisms of nonhealth significance (in lieu of thermal processing).


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