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The Food Scientist

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Posted 20 July 2022 - 08:05 PM

Hello,

 

Quick question, before I contact FDA about this question.

 

So we are a juice bottling company. Basically bottling juice after it gets pasteurized. All juices have a pH of 4.4 and below.

 

Our 3 CCPs are the pasteurizer, in-line magnet, in-line strainer. so Biological and physical hazards. 

 

We have a smoothie mix that uses coconut water (again final product pH is 4.4). now a new supplier for a coconut water has identified C. botulinum as a hazard in their HACCP plan. So then obviously we have to include into ours. We already have Salmonella in it, (CCP is Pasteurizer HTST). so knowing our product and process, C.botulinum will not even survive in it because our pH is under 4.6 (nature of our product will always be that pH since every single raw material we have have a pH of under 4.6).

 

Question and argument with others is, will pH be a CCP in this case? that we will have to add it as a 4th CCP in this product that uses coconut water?

 

My argument is that the inherited characteristic of this product doesnt even have a pH of above 4.6. so either way it wont be over it in this process. Unlike HTST, magnet or strainer, that we add to the process to eliminate the hazards.

 

Like to hear what everyone thinks about this!


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The Food Scientist

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Posted 20 July 2022 - 08:31 PM

Okay max spec for the pH for this product is 4.2 not 4.4.


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Brothbro

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Posted 20 July 2022 - 08:48 PM

Given than Cbot is a hazard in the coconut water's process, how is the product packaged/processed? If it is a commercially sterile, shelf stable product should this not be controlled on the supplier end rather than pH testing on yours? Your part may amount to supplier qualification activities rather than pH monitoring.

 

I'm not too familiar with juice processing in the pH<4.6 range, but is your pasteurization process developed by a process authority? Is there no mention from them that the process is only effective given the fact that the pH stays below 4.6 (ie hurdle tech)?


Edited by Brothbro, 20 July 2022 - 08:59 PM.


The Food Scientist

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Posted 20 July 2022 - 09:01 PM

they are performing their temperature processing (the supplier) but their packaging is not sterile and it is NOT shelf stable. 

 

apparently they're doing 121.5 C for 192 seconds. but they are temperature controlling their drums of coconut water still.


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Brothbro

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Posted 20 July 2022 - 09:08 PM

Hmm that is odd, I have experience with commercial sterility, but a coconut water product like that is outside of my realm a bit. I'd hesitate to offer much detailed advice. Perhaps ask yourself: Does the coconut water carry a reasonably likely risk of introducing C-bot (a significant pathogen) into your product? If so, how are you controlling for that hazard? If your justification is to rely on the pH of your product, it may be necessary to introduce pH as a CCP. Perhaps contacting a process authority would be of interest to your company as well.


Edited by Brothbro, 20 July 2022 - 09:10 PM.


Scampi

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Posted 21 July 2022 - 11:51 AM

I would ask to see some COA from their lab to know what levels of c botulism you're dealing with.  My concern would be growth prior to processing (after they produce and before you use)

 

You may need to amend your pH slightly to ensure the bacterium cannot be reactivated

 

And until you know those things-I would err on the side of adding it as a CCP-but as the receiving step.  If the pH isn't 4.2 or lower, you should be able to amend your recipe with citric or acetic acid to lower it 

 

You'll definitely want to reach out to a process authority on this one


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jfrey123

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Posted 21 July 2022 - 06:57 PM

Dumb question (because I like to learn through other user's experiences):  is the coconut water added before or after your pasteurization?  If before, could you include it as a pathogen hazard in that step with validations to prove it's safe?  If you end up counting on ph levels as the control measure for the coconut water, then I'd imagine your ph will indeed become a CCP instead of the side effect of your process.



Brothbro

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Posted 21 July 2022 - 07:23 PM

Dumb question (because I like to learn through other user's experiences):  is the coconut water added before or after your pasteurization?  If before, could you include it as a pathogen hazard in that step with validations to prove it's safe?  If you end up counting on ph levels as the control measure for the coconut water, then I'd imagine your ph will indeed become a CCP instead of the side effect of your process.

 

No such thing as dumb questions jfrey123! My understanding is that yes, the coconut water is mixed with other ingredients in the smoothie mix before pasteurization. However, given that the hazard is specifically clostridium botulinum, the pasteurization process (HTST) will not reach temperatures high enough to kill the cbot spores. Therefore, pH would instead be relied upon to control cbot (if cbot is indeed expected to dwell in the coconut water). 

 

To kill cbot spores, facilities must employ ultra-high-temperature (UHT) aseptic processing, which results in a commercially sterile product. You'd recognize these products as shelf stable cans, or shelf stable flexible packages (ie TetraPak)

 

https://www.idfa.org/pasteurization


Edited by Brothbro, 21 July 2022 - 07:25 PM.


Charles.C

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Posted 23 July 2022 - 05:02 AM

Hi TFS,

 

There are several threads here on coconut water though mostly not haccp-oriented..

 

Maybe initially have a look through this one -

 

https://www.ifsqn.co...ect/#entry82125

 

The link inside this link also looked potentially interesting (still active) although maybe focused on sterilization, not pasteurization -

 

https://www.ifsqn.co...ty/#entry153852

 

This is FDA link although no doubt already only too familiar to you -

 

https://www.ifsqn.co...nts/#entry87346


Kind Regards,

 

Charles.C




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