16 replies to this topic

[Ives101]

Hi

 

Anyone here involved on the HACCP development of non-alcoholic beverages?

 

Have you considered the %ABV (Alcohol by Volume) legal limit as one of your CCP and why? 

 

 

TIA!

 

 

Cheers, 

[pHruit]

Is this for general soft drinks, or are you specifically looking at e.g. a dealcoholised product where achieving a specific maximum level of alcohol through a reduction process is necessary to achieve a label claim / comply with a regulatory requirement?

I don't think I've ever seen it as a CCP in "normal" soft drinks manufacture.

 

Are you working with any specific certification standards? The idea that alcohol is a chemical hazard is something that I suspect could lead to some interesting discussions with auditors.

In a strict HACCP sense, there is perhaps also a question of the severity of the safety risk associated with this - for example, even if you need to achieve dealcoholisation do <0.5%ABV for a regulatory requirement, is there an actual food safety risk if the product ends up at 0.6%, given that a consumer can easily buy spirits at >40%ABV? It certainly could be a "legal" risk, but exactly how you want to approach/categorise that may depend on which certification standard(s) you're working with, as they seem to have diverged in their interpretations (/corruptions?) of Codex HACCP

 

For standard soft drinks there is a theoretical risk of a higher ABV levels if you're using a lot of flavourings carried on ethanol, but I don't think I've ever seen that handled in any way other than via the NPD process, so would perhaps be grouped under prerequisite programs. Similarly for flavourings with other components for which there are specific maximum levels in finished products defined in regulation.

[Charles.C]

Hi

 

Anyone here involved on the HACCP development of non-alcoholic beverages?

 

Have you considered the %ABV legal limit as one of your CCP and why? 

 

 

TIA!

 

 

Cheers, 

 

Hi Ives,

 

As per Post 2, some process "clarification" is needed.

 

For example, here is FDA's Juice HACCP -

 

https://www.fda.gov/...-guidance-first

 

"ABV" per se could presumably manouevre into the Quality and/or Legality portion of BRC's Global Safety/UTC Standard or SQF's Quality Code. Or perhaps even the Fraud element in BRC's "corrupted' HACCP.

[baziola]

In Ontario Canada, we have a legal requirement to maintain our ABV at or below 0.50%. Our CCP in our HACCP plan is pH. We have identified that a pH of 4.5 or below is sufficient for food safety. We however do routinely have a pH of 4.3 and below to ensure that we have no pH shift. We do pasteurize our products as a sidebar for additional food safety and stability.

[Scampi]

In Ontario Canada, we have a legal requirement to maintain our ABV at or below 0.50%. Our CCP in our HACCP plan is pH. We have identified that a pH of 4.5 or below is sufficient for food safety. We however do routinely have a pH of 4.3 and below to ensure that we have no pH shift. We do pasteurize our products as a sidebar for additional food safety and stability.

 

 

Under which regulatory body?  Health Canada?

[hello.fizz]

Could it be considered a QCP instead? 

[foodie13]

Late to the game on a reply here, but my food safety plan indicates who my target consumers are.  If your intended consumer could be a child or a pregnant woman, then having alcohol above the legal limit would be a safety consideration no?  Alcohol is not recommended for people under the age of 21 in the US or for pregnant women.  If I was going to use alcohol as a CCP that would probably be my justification. Is that reasonable? 

[Ives101]

Agree to that, Foodie13. Appreciate your input.

 

Thank you!

[SHQuality]

Another issue to consider is that your label can only deviate from the actual contents by a certain amount.

In EU legislation there is a document that specifies how large those deviations are allowed to be.

 

Do other countries/areas have similar tables?

[foodie13]

Yes, in the US there is also a tolerance for how much a product can deviate from the label alcohol content claim.

I was seeing that as more regulatory and taxes concern than a direct food safety concern though (and therefore not a CCP). Consumers wouldn't get sick if my 6% alcohol (label claim) was actually 5.5%.

Do you see it differently?

I could see maybe a minimum alcohol content is a CCP for food safety purposes, but then the product would be grossly out of compliance for the label claim in most cases and unlikely to ever be at that minimum limit.

[G M]

Hi

 

Anyone here involved on the HACCP development of non-alcoholic beverages?

 

Have you considered the %ABV (Alcohol by Volume) legal limit as one of your CCP and why? 

 

 

That seems like an odd CCP for most beverages that normally do not contain alcohol.   If your milk or fruit juice is fermenting enough to be measurably alcoholic, by accident, I would expect there to be a more general microbiological problem that you should already be testing for.

 

I can't really imagine having enough micro growth to result in 0.5% ABV and not fail the micro testing by a lot.

[SHQuality]

I utterly misread the original question. I thought it was about alcoholic drinks... Oops.

 

If a product is considered a non-alcoholic beverage, you shouldn't really be able to measure any alcohol formation at all. Any measureable amount of alcohol is a food safety risk for children. (and any adult that doesn't expect alcohol to be present). You may be able to argue less than 0.5% based on label deviations, but that is already getting iffy.

[pHruit]

That seems like an odd CCP for most beverages that normally do not contain alcohol.   If your milk or fruit juice is fermenting enough to be measurably alcoholic, by accident, I would expect there to be a more general microbiological problem that you should already be testing for.

 

I can't really imagine having enough micro growth to result in 0.5% ABV and not fail the micro testing by a lot.

I certainly agree that it would be an unusual CCP, although I wouldn't be at all surprised by a detectable ethanol level in a fruit juice without failing micro. There is often some initial ethanol production by yeasts prior to initial processing, and that processing typically then kills (or should kill) the yeast such that the raw material as received by a soft drinks manufacturer would be microbiologically fine.

 

Ethanol content and similarly acetic and lactic acid content are often used as indicators for good hygiene practice earlier in the supply chain, and for example in Europe the juice industry association (www.aijn.org) code of practice sets a maximum of 3.0g/L (0.3%w/v) for ethanol content based on juice at single strength - for something like a 6-fold concentrate you could therefore find almost 1.8%w/v ethanol content in a product that has been produced "correctly".

[foodie13]

Most flavors are alcohol based flavors. Depending on the amount of flavor you have in your beverage formulation, you can very easily start creeping up to 0.5 %ABV.  "Soda" type beverages with added juice and a lot of flavoring can have measurable amounts of alcohol right at blending (definitely not a result of micro issues).  In the US 0.5% ABV is the max allowable for a product considered non-alcoholic so it is definitely something we have to watch out for in the formulations of non-alc products.

 

Another consideration is if there are fermented ingredients in the formulation. Depending on the type of yeast, you may get more or less alcohol production which can then put you over the limit on final formulation. 

[GMO]

Any measureable amount of alcohol is a food safety risk for children. (and any adult that doesn't expect alcohol to be present). You may be able to argue less than 0.5% based on label deviations, but that is already getting iffy.

 

It's a bit doubtful 0.5% alcohol is any risk to a child.  You can buy shandy in the UK which is made from bitter (ale) with lemonade.  It has an ABV of no more than 0.5% and is on sale to kids without any restrictions.  

Alcohol does cause harm but the harm is more likely to be chronic long term rather than acute unless it's a very large volume.

[qualityhr]

I am the QM at a dietary supplement company that makes herbal tonics. We claim on the label that the tonics are alcohol-free, but do not have ABV as a CCP. However, I'm beginning to wonder if we should be sending out samples on a regular basis to be tested for ABV since we make this claim but don't control it through a CCP for each batch.

 

Does anyone have thoughts or advice on this?

[Ives101]

@qualityhr

 

If you are able to demonstrate that finished products are verified on a set frequency to ensure compliance to your ABV-free claim, doesn't necessarily need to be tested by an external laboratory. External testing could be done annually as an example.