Micro Testing Limits for Hemp Seeds and Oils
I'm looking for additional information on micro testing limits for hemp seeds and oils in the US. I haven't been able to find a whole lot in my searches, as this is a fairly "young" industry, but I am trying to help establish testing limits for our specs. Mostly, I've been able to find general information from the FDA draft guidance on seeds and nuts, but nothing more specific. Since the seeds are considered both raw and RTE at the same time, I was wondering if I should consider this similar to fresh fruits/vegetables?
Thanks in advance for any direction on this!
Which guidance are you refering to?
For most ingredients the FDA doesnt establish micro limits for most products. Only that the product is safe to consume. Unless you are follwoing the FSMA exemptions for not controlling a hazard, I would only consider the product RTE. (you dont know how the customer will use / consume)
Other micro limits would depend on how and if the seeds are processed. IE have they been roasted or through some type of heat step, ETO treated, steam seriized, Irradiated (not sure its approved for hemp), etc. It may also depend on how th customer is going to use the product(s).
Here are some guidance docs I referred to:
- Draft Guidance for Industry Hazard Analysis and Risk-Based Preventive Controls for Human Food: Appendix 1 (January 2024)
- GRAS Notices
- Microbiological Testing by Industry of Ready-to-Eat Foods Under FDA’s Jurisdiction for Pathogens (or Appropriate Indicator Organisms): Verification of Preventive Controls
We anticipate some customers to consume the product without further processing, and we do not currently apply a heat/sterilization step, but we are researching this as well. We don't know what an appropriate APC limit would be or if we should just test for pathogens and toxins and skip APC. I'm hoping there are some resources out there somewhere, maybe regarding what others do currently or what is common in the seeds/grains/oils industry.