18 replies to this topic

[mindy]

Dear everyone,

 

I am working to have the quality docs for chocolate. This is a new product in our facility, so it is difficult for me to finish haccp plan related to chocolate to meet requirements of BRCGS when auditing

The main raw material is milk/dark chocolate, after that we will add food color --> warm at temp. about 40 degree C, --> pour mold (with tray)-->cooling --> packaging. Product is RTE

Milk/dark chocolate are analysed for Salmonella by the supplier. We do not have the laboratory. We only send finished product to the external lab for testing.

Product will be stored in ambient. So, I think it belongs low risk area according to figure 5 of production zone decision tree 2 (BRCGS)- Answer "No" for Step 5 of BRCGS. Pls give me if I am correct?

I known that chocolate were regarded as microbiologically safe due to the inherent product characteristics such as low moisture and aw. However, Salmonella in chocolate-derived products has caused several outbreaks and recalls in recent years

The matter is our production line no step destroy or reduce this pathogen, if so that it is safe for finished product? 

I quite confused how to effective control pathogen in haccp plan if only expect on result showed on CoA  is Sal not detected from supplier

 

Thanks in advance

Edited by mindy, 10 April 2024 - 09:31 AM.

[Scampi]

Keep water away!   Once water is introduced to the process, that is when you'll enter the salmonella issue

 

BTW-why adding food colour to milk/dark chocolate-----it won't change the colour???

 

Google chocolate manufacturing, there is actually quite a lot of good information out there

 

Cocoa butter is used to purge the machines between types, you can then use that in the next batch of the same type

 

KEEP IT DRY

[GMO]

My understanding is chocolate is the reason for ambient high care to exist because it is so sensitive to Salmonella in that a very small count can cause illness.  

In the description of Ambient High care it says this:

 

"The finished products are such that vegetative pathogens could survive and grow in normal use, subsequently causing food poisoning, or are of a nature (e.g. fatty foods) that enables food poisoning to result from a very low level of contamination with a pathogen."

 

That is describing chocolate to a T.  BUT it suggests that it's only applicable if you have the raw beans on site as it goes on to say:

"Examples of processes that require an ambient high-care processing area include the manufacture of chocolate from raw cocoa beans, the production of milk powder from raw liquid milk, or the manufacture of peanut butter from raw peanuts"  

Personally, I would adopt the requirements of ambient high care as sources of Salmonella are not just from raw meat but that's possibly going beyond the requirements of the standard.

[jfrey123]

Is the chocolate as a raw material sold to you as RTE?  If so, I think that helps your case in the HA.

 

I've toured a couple of chocolate factories and the process seems pretty simple to me.  I'd get some initial shelf-life studies going asap and submit a handful of test runs for salmonella testing.  I think that would give you a documented starting point to show the process is safe.

[mindy]

Dear  Scampi,

 

Many thanks for your prompt response.

 

Just want to clarify, add food color for milk chocolate only

 

One more time, thanks for you advice

 

 

Keep water away!   Once water is introduced to the process, that is when you'll enter the salmonella issue

 

BTW-why adding food colour to milk/dark chocolate-----it won't change the colour???

 

Google chocolate manufacturing, there is actually quite a lot of good information out there

 

Cocoa butter is used to purge the machines between types, you can then use that in the next batch of the same type

 

KEEP IT DRY

[mindy]

Good to hear from you. 

 

Yes, raw chocolate is RTE.

"HA", sorry, what does it mean? Pls clarify

 

"I've toured a couple of chocolate factories and the process seems pretty simple to me.  I'd get some initial shelf-life studies going asap and submit a handful of test runs for salmonella testing.  I think that would give you a documented starting point to show the process is safe." I really appreciate that, certainly this will help me solve my diffcult problem

 

I hope to hear from you asap

 

Thank you

 

 

 

 

Is the chocolate as a raw material sold to you as RTE?  If so, I think that helps your case in the HA.

 

I've toured a couple of chocolate factories and the process seems pretty simple to me.  I'd get some initial shelf-life studies going asap and submit a handful of test runs for salmonella testing.  I think that would give you a documented starting point to show the process is safe.

[GMO]

I've toured a couple of chocolate factories and the process seems pretty simple to me.  I'd get some initial shelf-life studies going asap and submit a handful of test runs for salmonella testing.  I think that would give you a documented starting point to show the process is safe.

 

Shelf life wouldn't help you here.  For those who haven't worked in chocolate, you don't need growth in chocolate to mean it's dangerous.  ANY level of contamination is potentially harmful which is why the change in standard to ambient high care.  It has to absolutely be a zero tolerance of S. spp. in your process.

 

Yes it is simple but it doesn't mean there haven't been issues.  (Ahem... Cadbury's...)

[Scampi]

Shelf life = the time for a product to no longer be edible 

 

Pathogen testing  = testing for the presence of pathogenic bacteria

 

One really has zero to do with the other

[jfrey123]

Shelf life = the time for a product to no longer be edible 

 

Pathogen testing  = testing for the presence of pathogenic bacteria

 

One really has zero to do with the other

 

Maybe it's because I'm in a fresh RTE product space, but when we do shelf-life testing through our certified labs, it includes pathogen tests.  Is this a unique thing my current company is doing?  (I'll admit I'm less experienced in this area working adjacently and not directly on these projects through my career).

[Scampi]

They are probably done in conjunction as part of a positive release program

 

the testing done is done for 2 distinctive reasons (here is a couple of examples of the difference) 

 

A shelf life study is the most effective way to determine the durable life or "best before" date of a prepackaged food and obtain evidence showing that the food will remain wholesome, palatable and nutritional until the end of the durable life

 

 

Pathogen testing is used to identify pathogenic organisms in manufacturing environments, ingredients or finished products that could harm the consumer.

[mindy]

Our raw material chocolate is white or dark compound, so identify potential hazards for B, C, P are significant hazards or not?

 

Is anyone advice or help me clarify this

 

Thanks in advance

[Dorothy87]

Hi Mindy

 

not sure what you meant by B (biological? / micro?) if so microbiological potential hazards must be identified. 

C- chemical, P - physical, 

 

some thoughts for micro (basic)

Presence of microbiological contaminants in raw materials from environment / place of growth (e.g., S. aureus, B. cereus, yeasts or moulds, E. coli, salmonella) or introduction of microbiological contaminants from processing / handling by manufacturer / supplier / equipment. Poor temperature control by manufacturer or supplier (where applicable), poor stock rotation by manufacturer or supplier /haulier (prior to delivery) causing multiplication of microorganisms. This typically does not apply to packaging. Post-processing contamination at manufacturer's site, contamination en route to their customers (if applicable), contamination at any other point in supply chain (if applicable). Potential for microbiological contamination from animal/pest by products during storage or haulage, or any intermediate steps in transit

 

physical 

 

Foreign matter in raw materials: ingredients or packaging ;  Intrinsic contaminants (not applicable for chocolate) Extrinsic contaminants, Post-processing contamination at manufacturer's site, Contamination at any other point in supply chain (if applicable).

 

chemical

 

Chemical contamination of raw materials or packaging. through processing or handling errors, e.g., cleaning chemicals, lack of procedural controls (temperature, time, etc.) or during transportation. 

 

In packaging: improper use of materials, e.g., inks or base materials, improper curing of plastics, etc.Plastics and plastic-coated cartons are often found to contain PFAS or BPA, which are both harmful to human health with long-term exposure. 

 

 

:)

Edited by Dorothy87, 15 April 2024 - 11:42 AM.

[mindy]

Hi dear,

 

Many thanks for your time to write down and explain clear, easy to understand

 

 

 

 

 

 

 

Hi Mindy

 

not sure what you meant by B (biological? / micro?) if so microbiological potential hazards must be identified. 

C- chemical, P - physical, 

 

some thoughts for micro (basic)

Presence of microbiological contaminants in raw materials from environment / place of growth (e.g., S. aureus, B. cereus, yeasts or moulds, E. coli, salmonella) or introduction of microbiological contaminants from processing / handling by manufacturer / supplier / equipment. Poor temperature control by manufacturer or supplier (where applicable), poor stock rotation by manufacturer or supplier /haulier (prior to delivery) causing multiplication of microorganisms. This typically does not apply to packaging. Post-processing contamination at manufacturer's site, contamination en route to their customers (if applicable), contamination at any other point in supply chain (if applicable). Potential for microbiological contamination from animal/pest by products during storage or haulage, or any intermediate steps in transit

 

physical 

 

Foreign matter in raw materials: ingredients or packaging ;  Intrinsic contaminants (not applicable for chocolate) Extrinsic contaminants, Post-processing contamination at manufacturer's site, Contamination at any other point in supply chain (if applicable).

 

chemical

 

Chemical contamination of raw materials or packaging. through processing or handling errors, e.g., cleaning chemicals, lack of procedural controls (temperature, time, etc.) or during transportation. 

 

In packaging: improper use of materials, e.g., inks or base materials, improper curing of plastics, etc.Plastics and plastic-coated cartons are often found to contain PFAS or BPA, which are both harmful to human health with long-term exposure. 

 

 

:)

 

[Snickerdoodle]

check for water activity and pH of your chocolate products. If the water activity is 0.6 or below, no micro proliferation. Perhaps this would help.

 FDA Hazard Analysis and Risk Preventive Control Human Foods Principal Groups of Foods Based on Water Activity (Aw) page 22

https://www.fda.gov/files/food/published/Draft-Guidance-for-Industry--Hazard-Analysis-and-Risk-Based-Preventive-Controls-for-Human-Food---Preventive-Controls-%28Chapter-4%29-Download.pdf

[GMO]

check for water activity and pH of your chocolate products. If the water activity is 0.6 or below, no micro proliferation. Perhaps this would help.

 FDA Hazard Analysis and Risk Preventive Control Human Foods Principal Groups of Foods Based on Water Activity (Aw) page 22

https://www.fda.gov/files/food/published/Draft-Guidance-for-Industry--Hazard-Analysis-and-Risk-Based-Preventive-Controls-for-Human-Food---Preventive-Controls-%28Chapter-4%29-Download.pdf

 

 

For those people who work in high risk foods where there is a potential for microbial growth, then water activity etc is relevant BUT there is something different about chocolate.  Due to the high fat content and food matrix, it protects any viable Salmonella in the stomach.  So I'll say this again, you do not need growth.  The low Aw is in no way protective.  If the Salmonella is there in ANY quantity, it can cause illness.

For people who have not worked in confectionery this will not be well known but it's the reason why BRC included ambient high care.  

There have been multiple recalls on this in the past.  The most recent being Kinder Eggs.  Considering so much chocolate is aimed at kids, I'd certainly be very very cautious about barrier control and hygiene in chocolate manufacturing.  

Kinder Surprise eggs recalled over salmonella link - BBC News
 

[mindy]

Many thank for your reply.

I agree with you that chocolate, although it has low water activity, ability prevents the growth of microbial hazard, however, there is potential for Salmonella contamination from added ingredients such as cocoa, milk powder which may contain Salmonella. 

Recall of Kinder products produced at a factory in Belgium in 2022 year is a proof

 

For those people who work in high risk foods where there is a potential for microbial growth, then water activity etc is relevant BUT there is something different about chocolate.  Due to the high fat content and food matrix, it protects any viable Salmonella in the stomach.  So I'll say this again, you do not need growth.  The low Aw is in no way protective.  If the Salmonella is there in ANY quantity, it can cause illness.

For people who have not worked in confectionery this will not be well known but it's the reason why BRC included ambient high care.  

There have been multiple recalls on this in the past.  The most recent being Kinder Eggs.  Considering so much chocolate is aimed at kids, I'd certainly be very very cautious about barrier control and hygiene in chocolate manufacturing.  

Kinder Surprise eggs recalled over salmonella link - BBC News
 

Edited by mindy, 07 May 2024 - 03:00 AM.

[Tony-C]

Hi Mindy,

 

I quite like the information provided in the new Hazard Analysis and Risk-Based Preventive Controls for Human Food: Guidance for Industry by U.S. Department of Health and Human Services Food and Drug Administration Center for Food Safety and Applied Nutrition - January 2024

 

 Biological Hazards Chocolate.png   533.57KB   9 downloads

 

Also see Table 3-3. Examples of Pathogens Identified from Outbreaks Attributed to Contamination with Environmental Pathogens, these include:

 

Chocolate - S. Napoli - Possibly contaminated water used in double-walled pipes, tanks and other equipment - Ref. Gill, et. al. (1983)

 

Chocolate - S. Eastbourne - From processing environment - Ref. Craven, etc

 

The Guidance lists all references cited in the chapters, for example:

 

Craven, PC, DC Mackel, WB. Baine, WH Barker, and EJ Gangarosa. 1975. International outbreak of Salmonella eastbourne infection traced to contaminated chocolate. Lancet 1 (7910):788-92.

 

Gill, ON, PN Sockett, CL Bartlett, MS Vaile, B Rowe, RJ Gilbert, C Dulake, HC Murrell, and S Salmaso. 1983. Outbreak of Salmonella napoli infection caused by contaminated chocolate bars. Lancet 1 (8324):574-7.

 

The Brussels Times. 2022a. Chocolate contamination: Salmonella traced to Hungarian delivery.

 

The Brussels Times. 2022b. Hundreds of tonnes of chocolate destroyed following salmonella outbreak.

 

I agree with GMO’s posts, if you google Salmonella and Chocolate I’m sure you will find many more examples, for me the Cadburys example is a classic: Cadbury pleads guilty in salmonella case

 

The outbreak was caused by Salmonella contamination but also by someone in Cadburys deciding that there was a “safe” level of Salmonella in chocolate which they have subsequently admitted was wrong.

 

BRCGS gives examples of processes that require an ambient high-care processing area and these include the manufacture of chocolate from raw cocoa beans, the production of milk powder from raw liquid milk, or the manufacture of peanut butter from raw peanuts.

 

Back to the Guidelines, there are also Physical Hazards (General) and Chemical Hazards (Cadmium, Lead & Ochratoxin) for you to consider:

 

 Chemical Hazards for Chocolate.png   417.44KB   4 downloads

 

 Physical Hazards General.png   443.09KB   4 downloads

 

Kind regards,

 

Tony

 

[mindy]

Dear Tony,

 

Thank for your articles and the links

It provides tons of useful information for me to complete chocolate haccp plan

 

Hi Mindy,

 

I quite like the information provided in the new Hazard Analysis and Risk-Based Preventive Controls for Human Food: Guidance for Industry by U.S. Department of Health and Human Services Food and Drug Administration Center for Food Safety and Applied Nutrition - January 2024

 

Biological Hazards Chocolate.png

 

Also see Table 3-3. Examples of Pathogens Identified from Outbreaks Attributed to Contamination with Environmental Pathogens, these include:

 

Chocolate - S. Napoli - Possibly contaminated water used in double-walled pipes, tanks and other equipment - Ref. Gill, et. al. (1983)

 

Chocolate - S. Eastbourne - From processing environment - Ref. Craven, etc

 

The Guidance lists all references cited in the chapters, for example:

 

Craven, PC, DC Mackel, WB. Baine, WH Barker, and EJ Gangarosa. 1975. International outbreak of Salmonella eastbourne infection traced to contaminated chocolate. Lancet 1 (7910):788-92.

 

Gill, ON, PN Sockett, CL Bartlett, MS Vaile, B Rowe, RJ Gilbert, C Dulake, HC Murrell, and S Salmaso. 1983. Outbreak of Salmonella napoli infection caused by contaminated chocolate bars. Lancet 1 (8324):574-7.

 

The Brussels Times. 2022a. Chocolate contamination: Salmonella traced to Hungarian delivery.

 

The Brussels Times. 2022b. Hundreds of tonnes of chocolate destroyed following salmonella outbreak.

 

I agree with GMO’s posts, if you google Salmonella and Chocolate I’m sure you will find many more examples, for me the Cadburys example is a classic: Cadbury pleads guilty in salmonella case

 

The outbreak was caused by Salmonella contamination but also by someone in Cadburys deciding that there was a “safe” level of Salmonella in chocolate which they have subsequently admitted was wrong.

 

BRCGS gives examples of processes that require an ambient high-care processing area and these include the manufacture of chocolate from raw cocoa beans, the production of milk powder from raw liquid milk, or the manufacture of peanut butter from raw peanuts.

 

Back to the Guidelines, there are also Physical Hazards (General) and Chemical Hazards (Cadmium, Lead & Ochratoxin) for you to consider:

 

Chemical Hazards for Chocolate.png

 

Physical Hazards General.png

 

Kind regards,

 

Tony

[Snickerdoodle]

Thanks Tony. Very helpful info. I am also in the process of updating our HACCP Plan for Molded Chocolates.