9 replies to this topic

[Degger]

Greetings!  I'm currently writing a HACCP plan for a wholesale producer of crackers.  While reviewing the facility's flour invoices, I noted there was a statement at the bottom indicating the raw flour has not been processed in a manner to control bacteria.  

 

I've advised my client to look into changing processors so we are able to control this step at receiving. If the client stays with this processor, is there another control that may be applied here?

 

Once processed and proofed, the cracker dough is baked at 365°F for 19 minutes.  The end product is a flat, dry cracker, so recording temperatures is slightly difficult with anything but an IR thermometer.   My client has yet to have the product tested for pH and aW.

 

Here is where I'm stumped (it shouldn't be as difficult as I'm making it).  I haven't been able to find much supporting research regarding critical limits for controlling mycotoxins.  I was going to have the bake step as my CCP, but without critical limits, this is difficult.  

 

Does anyone have experience with this?  I'm irritated I'm hung up over something that should be so simple.  

 

Thank you for your input!

[GMO]

Why would you control the mycotoxin not the mould?

[kingstudruler1]

You usually cant "cook out" mycotoxins or other wise remove them.  I think the temp is 500+

 

You control mycotoxins with proper storage and handling from farm to finished process so that the molds that produce them dont grow and produce them.    It would normally be controlled with a prerequsite of some kind.  

 

Also, I wouldnt say that the precautionary statement from the supplier includes mycotoxins.  Mycotoxins are normally a chemical hazard.   

 

I would say that I am contolling them with and approved supplier prerequisite or supply chain PC ( in usa and im guesiing your are), proper storage on site, etc.    I would include some type of periodic monitoring for mycotoxins (send a sample to a third party lab, they may be on the COA (although Im not a fan of coas), etc    .....Do you due dillegence as it is a real risk.  

 

 

edit - if you store flour in bulk on site, you should have proper controls and monitor.   

Edited by kingstudruler1, 17 April 2025 - 02:45 PM.

[kingstudruler1]

For the bacteria, your cook step should be validated.   That would cover the pathogenic bacteria and elimintate the need for purchasing flour that has been processed to reduce / eliminate pathogens.   

[Scampi]

Why would you control the mycotoxin not the mould?

 

Because mycotoxins are the pathogen, moulds (most) are spoilage organisims

[nwilson]

There are action levels per commodity in each mycotoxin type per the FDA , Aspergillus and Penicillium are the general targets.  From my experience these mold have to proliferate quite extensively (meaning visibly contaminating a material) to have actionable levels of mycotoxins.   You can either test the material or have a supplier preventive control/PRP (as @kingstudruler1 stated).   Visual inspection can be used as well in conjunction with testing or having the supplier provide a COA.  

 

The supplier is providing a declaimer that pathogenic bacteria are not being controlled which is common for flour mills/suppliers, as the material is meant for further processing and a kill step.  Salmonella and E.Coli (STEC) are generally the pathogenic bacteria of concern.  The supplier should be testing at some interval for mycotoxins, which is common as they cannot be cooked out as it is a chemical contamination.  

 

Action level references

https://www.fda.gov/...food/mycotoxins

https://www.ams.usda...ference2017.pdf

[GMO]

Because mycotoxins are the pathogen, moulds (most) are spoilage organisims

 

Mycotoxin control is largely about prevention.  They do not spontaneously appear but do so from yeasts or moulds.  Etymology:  The word "mycotoxin" is derived from the Greek word "mykes" (fungus) and the Latin word "toxicum" (poison).

 

Hence, control your conditions to prevent the Y&M.  Then prevent the mycotoxins.

[Scampi]

My HACCP plan lists out mycotoxins specifically as so a lot of other plans

 

CFIA reference data base of hazards lists it out individually as well

 

The lot MAY be free of visible mould, but may contain mycotoxins from storage etc

[GMO]

Yep but I was meaning I agree, the mycotoxin is the hazard but you don't control it by testing.  You control it (and your suppliers do) by controls within their supply chain and yours to minimise risk of Y&M presence and growth do you not?  Your testing is then verification of those controls.

[fgfreuben]

FDA level is 1ppm for deoxynivalenol "DON" a.k.a. "vomitoxin"  for finished wheat products

 

also there are FDA levels for corn meal products regarding aflatoxin (20 ppb and fumonisins varies 2-4 ppm)

 

Probably others as well.

 

Your suppliers should guarantee this.

 

You can ask for copies of analyses (make sure it's from a certified lab).

 

Also you can analyze samples yourself or send them to lab to verify - maybe annually is good enough.