10 replies to this topic

[PQAManager]

We are mainly a beverage concentrate and syrup company and we just started a product that has an ingredient that is not food grade (diamaceous earth I think it's called) for animal attractant.  Is it allowed if the product is thoroughly cleaned after production before we start our beverage powder mixes?  I said no I don't approve, but I don't have the research to back me up.  Am I wrong or right?  Anyone have any FDA/SQF info that would support either?

[KellyQA]

So far, I am not seeing anything that states it can be used in human food. I am only seeing for animals and for indirect additives. 

I will continue to look for more information and if I am able to find more, I will share. 

 

 

FOOD ADDITIVES PERMITTED IN FEED AND DRINKING WATER OF ANIMALS

https://www.accessda....cfm?fr=573.340

 

 

§ 182.90 Substances migrating to food from paper and paperboard products.

Substances migrating to food from paper and paperboard products used in food packaging that are generally recognized as safe for their intended use, within the meaning of section 409 of the Act, are as follows:

https://www.ecfr.gov...pter-B/part-182

[PQAManager]

We don't use this ingredient in our powder drink mixes for humans, but the animal attractant is blended with the same equipment.

Edited by PQAManager, 03 April 2024 - 04:39 PM.

[jfrey123]

It was forever ago that my old family run spice company wanted to run bulk packages of diatomaceous earth through our food equipment to repack into smaller bags.  I was told, as a quality supervisor of a department of myself, that the execs had firmly decided to do it and I was not permitted to object.  I got a COA for the intended batch, and it declared a large amount of heavy metals (nickel, cadmium, chromium, bunch of them I can't remember).  I remember researching the quantities present and pointed out that they were in excess of what could/should be handled by humans without a significant level of PPE, and I had no clue whether we could clean the augers and packaging machines thoroughly to then run food through it.  I put my research into a memo and sent it to all the executives/family members, informed them I wouldn't sign off on anything related to it going through our food machines.

 

About 2 hours later, maintenance manager (also one of the named owners) wandered over to my desk like he often did to chit chat.  He asked me, "Is this stuff as bad as you make it sound?"  Showed him what I found, and he read it a bit.  "Alright, I'll tell these guys if they run it, then I'm not taking anything apart for cleaning.  Sounds like someone should tell them we're a food manufacturer."  He wanders off, conference room doors get closed with the family inside.  Few minutes before shift end, my production manager comes back to our office and lets me know the execs have decided to rent a separate warehouse suite next door and buy a used packaging unit somewhere to go ahead and run it under a different company name they owned.

 

Long story short:  My one experience with the stuff frightened me.  I was prepared to be fired or even resign; I didn't want to be implicated in anyway to heavy metal contamination of otherwise clean spices.  So check into a COA for what your plant is running and see if it shares any of the qualities I was concerned with way back in my story.  If you run through SQF code, various references are made to the safety of raw materials to be used within your processes:

 

2.3.2.2 Specifications for all raw materials and packaging, including, but not limited to, ingredients, additives, hazardous chemicals, processing aids, and packaging that impact finished product safety shall be documented and kept current.

 

2.3.2.4 Raw materials, packaging, and ingredients shall be validated to ensure product safety is not compromised and the material is fit for its intended purpose.

 

2.3.2.10 Specifications for raw materials and packaging, chemicals, processing aids, contract services, and finished products shall be reviewed as changes occur that impact product safety. Records of reviews shall be maintained.

 

2.4.3.7 The food safety team shall identify and document all food safety hazards that can reasonably be expected to occur at each step in the processes, including raw materials and other inputs.

[Setanta]

I can't imagine a scenario where I would accept this. Just based on jfrey123's experience, YIKES! 

[Scampi]

Diatomaceous Earth is composed of the fossilized exoskeletons of tiny organisms known as diatoms. These fossilized diatoms have very sharp edges allowing the diatomaceous earth to kill insects by lacerating their outer shells and dehydrating them.

When crawling insects come in contact with food grade diatomaceous earth it is much like crawling across shards of broken glass. The insects’ movement across the DE helps the razor sharp edges to lacerate its body.

https://www.azom.com...ArticleID=16463

 

 

Mined from the purest of deposits from prehistoric freshwater lake-beds, diatomaceous earth consists of finely milled silica shells of ancient microscopic freshwater plants called diatoms. Of 600 deposits in the U.S., only 4 rate in purity by FDA standards to label as "Food Grade". We are proud to say our diatomaceous earth comes from a mine that meets all FDA requirements to make it a food grade product. Our purity and safety also meets and exceeds requirements set forth by our government. We also are proud to say that all of our manufacturing procedures are compliant and exceed FDA requirements.

https://www.sproutma...food-grade-300g

 

 

iatomaceous earth is comprised of the fossilized remains of small, aquatic organisms known as diatoms. The fossilized skeletons are made of a natural compound known as silica. Over millennia, diatoms accrued in the sediment of various bodies of water. Today, silica deposits are extracted from these areas.

There are two fundamental kinds of diatomaceous earth: food grade, which is acceptable for consumption, and filter grade, which is toxic but has numerous industrial uses. Authorized for usage by the EPA, USDA and FDA, food grade diatomaceous earth has 0.5 to 2% crystalline silica and is primarily used as an insecticide and an anti-caking agent in the food production industry. Filter grade, or non-food grade, diatomaceous earth can include an excess of 60% crystalline silica. It is toxic to humans but has numerous industrial uses, including use in water filtration and as an ingredient in dynamite.

Silica is very common in nature and comprises 26% of the earth's crust by weight. While silica is fairly easy to locate, diatomaceous earth is a concentrated source of silica, which makes it distinctive. Commercially accessible diatomaceous earth is said to include 80 to 90% silica, many other trace minerals and small quantities of iron oxide.

Mined from the purest of deposits from prehistoric freshwater lake-beds, diatomaceous earth consists of finely milled silica shells of ancient microscopic freshwater plants called diatoms. Of 600 deposits in the U.S., only 4 rate in purity by FDA standards to label as "Food Grade". We are proud to say our diatomaceous earth comes from a mine that meets all FDA requirements to make it a food grade product. Our purity and safety also meets and exceeds requirements set forth by our government. We also are proud to say that all of our manufacturing procedures are compliant and exceed FDA requirements.

 

[kingstudruler1]

Is this for a animal feed / food product?

If its purpose is for anticaking, there are other options. I dont think its an attractant. 

If you are SQFI Certifed, you will add animal feed to your scope or will you  exclude it from your certificate?   You need to get there take as it sounds like a major change.

 

There are food versions of DE and it is OK for SOME applications.   examples: animal feed flow agent, filtration aid, etc.  

 

Like others it seems like there is alot of risk that should be evaluated.  I like to find ways to make things work, but sometimes............

 

https://www.fda.gov/...560772-06072019 (see adulterated human food section)

 

https://www.accessda....cfm?fr=573.340

[G M]

Broadly speaking, you would need to be able to ensure through validation and verification that no trace of any hazardous material remained on the equipment before resuming food production.  No different than if it had become contaminated with filth.

 

Given some of the other posters background on DE and the levels of toxic contaminants it could contain, I would be extremely reluctant to introduce anything like that without a very strong cleaning and testing program to deal with it.

[SQFconsultant]

Been using the food grade version for years now, check out HARRIS brand. 

[PQAManager]

What about Cattle salt that is not food grade?

[G M]

What about Cattle salt that is not food grade?

 

The exact item is kind of irrelevant, and the response is the same.  There has to be a validated and testing verifiable cleaning process that will remove every trace of the not food-grade material before you can switch back to food production.  It is filth or "adulteration" as far as the regulators are concerned.

 

You will have to prove that your cleaning process is capable of removing it entirely and returning the entire production environment to an acceptably sanitary condition, then when you actually do this change-over perform testing to verify it every time.