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SQF-2.4.8 - Is an Environmental Program Required?

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MikeCL98

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Posted 25 January 2024 - 02:24 PM

Started new job in a coffee roasting facility. Prior to my arrival only audits required were FDA and General GMP. The company is wanting to certify to SQF. I come from a meat and RTE industry. Coffee roasting is low risk and has consumer steps for it to be consumable. Doing my due diligence of research in coffee as it is a new product to me, I have discovered these factors: low risk, roast is 13 mins for 420F, dry clean only facility, not consumed raw, and requires consumer brewing for consumption (195F to 205F brew temperatures for water). 

Going through SQF-2.4.8 and applying risk factors which rate dry roasted coffee as low (very low) and no history of micro issues in past with recalls or reported illnesses. 

Based on this would/could we be able to be exempt from SQF-2.4.8 based on justifications of dry roasted coffee presented and not have to test for spoilage, indicator, or pathogenic bacteria?

Regardless of justifications does SQF require mandatory testing even though risk does not justify it?

 

Needing advice as I was in BRC programs in RTE facilities 10 years ago and have never dealt with SQF in a coffee roasting facility. 

 

Thanks!!!!



fgfreuben

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Posted 25 January 2024 - 02:52 PM

Probably annual zone 2 bacterial - salmonella etc., possibly annual product salmonella also?  This is pretty much what we do for flour.  What about cold brewing coffee???



MikeCL98

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Posted 25 January 2024 - 03:11 PM

Probably annual zone 2 bacterial - salmonella etc., possibly annual product salmonella also?  This is pretty much what we do for flour.  What about cold brewing coffee???

No cold brewing. Only dry roasting green coffee beans then packaging roasted beans. 



fgfreuben

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Posted 25 January 2024 - 03:17 PM

consumers could be cold-brewing the coffee ... even though flour is ready-to-cook we still test for salmonella because it's a potential foreseeable consumer action.



SQFconsultant

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Posted 25 January 2024 - 06:09 PM

Have coffee bean roaster as client and they exempted themselves thru risk assessment. Not an issue.

 

Do you import green ? And are you trailer fumigation  or is this done prior to arrival?


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development, Implementation & Certification | eConsultant | Internal Auditor Training

http://www.GCEMVI.XYZ

https://glennoster.website3.me/

 


MikeCL98

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Posted 25 January 2024 - 06:12 PM

Have coffee bean roaster as client and they exempted themselves thru risk assessment. Not an issue.

 

Do you import green ? And are you trailer fumigation  or is this done prior to arrival?

We do not import but roast green beans from well established long time supplier(s). 



acarver

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Posted 25 January 2024 - 07:16 PM

We are a small roaster. We have do have a simple risk-based EMP. Since the testing is more for environmental hazards, our RA focuses on the risks introduced by employees.



MikeCL98

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Posted 25 January 2024 - 07:18 PM

We are a small roaster. We have do have a simple risk-based EMP. Since the testing is more for environmental hazards, our RA focuses on the risks introduced by employees.

Would you be willing to share some of your EMP with me to assist in our decisions and plans. My meat background is way overkill for roasted coffee.



acarver

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Posted 25 January 2024 - 07:33 PM

Would you be willing to share some of your EMP with me to assist in our decisions and plans. My meat background is way overkill for roasted coff

Yes, but unable to message the information to you? 



jfrey123

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Posted 25 January 2024 - 07:46 PM

FDA Hazard Analysis shows the roasted beans and ground coffee do have a chemical hazard for mycotoxins.  Could be you get away with not swabbing for pathogens, but maybe some monthly tests for Y&M to show no issues could be worth checking into, and after a few months of negative tests you could move to a quarterly monitoring program.

 

Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food - Appendix 1 Tables (fda.gov)

 

You can write SQF and exempt yourself from a program element that isn't mandatory (such as 2.4.8).  You'd have to have some killer justification to exempt, and I'm tracking with your logic in general, but might not be strong enough without some data to back it up.



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MikeCL98

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Posted 25 January 2024 - 07:47 PM

Yes, but unable to message the information to you? 

How to network?



acarver

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Posted 25 January 2024 - 09:01 PM

How to network?

Click my name see if you can send me a PM. We can go from there. I am unable to send you a PM.



MikeCL98

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Posted 25 January 2024 - 09:08 PM

Click my name see if you can send me a PM. We can go from there. I am unable to send you a PM.

Did not work, but mssg here. production at independence coffee dot com. username as subject. 



Hoosiersmoker

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Posted 01 February 2024 - 05:52 PM

We had an exemption from EMP (manufacturer of packaging) and after SQF Ed 9 was implemented, I was told told the auditor will look at the risk assessment and evidence and make a determination of whether an exemption is still acceptable. The last time I requested information on that exemption I got this response:

“I’m happy to advise that for the next audit against V.9 of the standard you won’t need a formal exemption

Since there is now only the requirement below applicable to Products and not anymore also to elements of the code."

(He cited 3.1 Exemptions, first sentence referencing products. "3.1 Exemptions - If you wish to exempt any products processed or handled...")

"The requirements can be evaluated as Applicable or not, base on your risk assessment and the Auditor judgment.

I will look for some SQf guide on the evaluation and will advise soon if I find something.” - Alessio Lelario

Technical Scheme Owner F&B

 

Hope this helps


Edited by Hoosiersmoker, 01 February 2024 - 05:52 PM.


tnguyen1300

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Posted 01 February 2024 - 06:17 PM

We are also a coffee roasting manufacturer and SQF certified. Our EMP is implemented to determine our sanitation program's effectiveness. We do quarterly testing which included pathogen swab testing on equipment and building construction along with annual air monitoring





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