Antioxidant & Ash in Raw Material

Hi!

I have a dilemma here regarding Risk Assessment.

In the food manufacturing company where i work in, we use many types of raw materials. In the information provided by our suppliers, many of these raw materials have "ash" or "antioxidant".

When building the Risk Assessment, should they be considered as hazard, and if they are, which category of hazard (Biological/Physical/Chemical) should i put them in?

Hi!

I have a dilemma here regarding Risk Assessment.

In the food manufacturing company where i work in, we use many types of raw materials. In the information provided by our suppliers, many of these raw materials have "ash" or "antioxidant".

When building the Risk Assessment, should they be considered as hazard, and if they are, which category of hazard (Biological/Physical/Chemical) should i put them in?

Can anybody help our newest member Eugene with this query?

Thanks,
Simon

Dear EuGeNe,

Regarding antioxidants, I suppose the general answer to yr query is yes although any specific hazard potential presumably depends on what the compound is (normally this should be in the product spec., or if otherwise, requested / demanded ??).

One brief definition I googled is –

Antioxidant — Chemical approved for the control of oxidation (rancidity) in food products. USDA approved antioxidants include: BHT, BHA, propyl gallate. Regulations limit concentration to 0.003% for individual chemicals, 0.006% for combinations.
http://www.nysaes.co...e/glossary.html

This agrees my own opinion to regard as included in the “Chemical” grouping although I have also seen it in the Biological section, eg –
http://www.ais.mssta...sson8/haccp.htm

The above definition also suggests the requirements to be a HACCP non-hazard such as approval for use (eg GRAS or USFDA/Codex referenced), food grade, used in the appropriate manner etc.

“Ash” . It presumably similarly depends on what is in the ash. Normally expected to be mainly mineral residues. Heavy metals ?? Hopefully any such items would again be covered / controlled via the product specification itself ?. Or perhaps you have something more specific in mind ?

Rgds / Charles.C

Dear Charles,

The raw materials mentioned are processed by the suppliers and used as it is on our side, which means that we do not do any additional processing on the raw materials received.

Do you mean that if the antioxidant and ash are covered in the product specification, then a risk assessment is not required?



Danke,
Eugene

Dear Eugene,

Well, the decision regarding yr product / ingredient specifications (hopefully) routinely includes a validated risk assessment step (although I suspect it is not so rare that it occurs after production has commenced ). The exact procedure will depend on your product/process and chosen HACCP methodology. Many people consider aspects of incoming materials within the Prerequisite stages but this is not mandatory (except I22k maybe?). As an example, you can see one formalised, logical approach to the handling of various BCP hazards (inc. antioxidants) in a HACCP plan for assembled pizza production here –

http://www.inspectio.../pizza6ae.shtml

and

http://www.inspectio...a/pizza8e.shtml

Suppliers tend to be rather secretive IMEX regarding composition details of food additives (and many other potential food contact products,eg detergents) but then the user unfortunately becomes the one taking the risk. One approach is to issue lists of officially approved products as mentioned in above website but final destination regulations may still be more restrictive - - hence the employment of QA staff .

Rgds / Charles.C

Hello Eugene,

My point of view is that you can have both of these issues :

For instance you have an antioxidant which allows you to improve your BBD, 25g/ kg is the right quantity, critical limits 15g/ kg and 35 g/ kg

- if you are below the low limit (15g/ kg), you have a risk not to have your required BBD because of microbiological issues - not enough citric acid ==> bacterial growth you can't control : a biological hazard.

- If you are above the high limit (35g/ kg): a chemical hazard. It depends on your antioxidant, some of them have to be used in limited concentrations. If you exceed this limit, it occurs some issues - because of allergens, action of your antiowidant, requirements of the laws country you have to keep in mind for your Haccp plan.

Hope it will help you,

Regards,

Emmanuel.

Dear Charles,

According to pizza risk assessment, not all identified hazards requires control measures.

Upon viewing the link you provided, i have some further queries. Is it necessary to have a control measure for every identified hazard?

If so, are there any parameters to decide whether a particular hazard requires control measure or not?




Thanks Penard for your advice. I understand your idea of distinguishing the hazards based on the upper and lower limit. However, the raw materials are not analysed once received, and therefore we depend only on the declarations of the supplier. Hence, as mentioned above, maybe it might not be necessary to implement control measures.

Dear Eugene,

According to pizza risk assessment, not all identified hazards requires control measures.

Upon viewing the link you provided, i have some further queries. Is it necessary to have a control measure for every identified hazard?

If so, are there any parameters to decide whether a particular hazard requires control measure or not?

Not quite sure I understand the exact meaning of your “identified hazard”. The general answer is in this link -

http://www.inspectio...nue/app3e.shtml

If yr "identified” means a hazard which has been analysed as equivalent to a CCP or prerequisite, then some control measure is required “somewhere”. If no control measure is possible, either the process has to be redesigned, ( eg see top portion of the Ctree diagram in this link (pg47))

http://www.haccphelp...ments/Codex.pdf

or it must be accepted that a safety risk may exist (eg eating raw oysters without any idea as to their origin and/or unknown confidence in prior handling ).

Hope this helps, if I’ve misunderstood yr query, please revert with more specific example.

Rgds / Charles.C

Dear Charles,

I hope the following explanation may clarify the situation.

All raw materials are sourced from suppliers. The suppliers are not HACCP certified. Suppliers provide CoA for every batch of raw materials sent to our side. Based on the CoA declarations, my company receives the raw material as it is. No futher analysis are done on the raw materials.

Therefore in identifying the hazards for raw materials, are i still susceptible to include the items in the CoA?

For example: Antioxidant is in the CoA, do i still have to identify BCP hazard for antioxidant? Also, does every BCP hazard that is identified requires to have a control measure? Because if i do identify antioxidant as a BCP hazard, then i will not have the necessary control measures since no analysis is done.

Im sorry about the complexity of the situation. Im not very good at explanation and i have thought about this matter for quite a long time yet i cannot come to a good conclusion. I was hoping you guys can give some opinions/ideas on how to go about this matter.

Thanks a lot!

Dear EuGene,

All raw materials are sourced from suppliers. The suppliers are not HACCP certified. Suppliers provide CoA for every batch of raw materials sent to our side. Based on the CoA declarations, my company receives the raw material as it is. No futher analysis are done on the raw materials.

I would suggest you to occasionally send few samples of your raw materials for chemicals tests to correlate the data specified on the COA with the results obtained from chemical tests done from your sampling this will help your in assessing your supplier performance and the suitability.

For example: Antioxidant is in the CoA, do i still have to identify BCP hazard for antioxidant? Also, does every BCP hazard that is identified requires to have a control measure? Because if i do identify antioxidant as a BCP hazard, then i will not have the necessary control measures since no analysis is done.

In this case your control measure will be to control your suppliers by auditing your approved suppliers and ensure the raw materials entering your facility are safe by conducting the required tests whether chemical or microbiological from your end once in a while.

Therefore in identifying the hazards for raw materials, are i still susceptible to include the items in the CoA?

There are limitations which impel us to choose critical sensory parameters in our organoleptic evaluation program, hence there is a pressing need to carry out further studies to evolve appropriate science based parameters to correctly indicate the extent of including it in the hazard list.



I hope this was able to provide some useful suggestion.



Regards,



J

Hhmm... fully understood. I'll see if i can work out some magic on this side.

Thanks jean for your reply.

Special thanks to Charles, Penard and Simon for your time and effort in guiding.

Dear Eugene,

As Jean indicated, you have to trust other people's ingredients to not be a hazard.

The question then becomes - what are the minimum requirements necessary for you to make that decision, eg (a) is the specific antioxidant/usage approved for use with respect to the intended destination (particularly if there will be definite residues in the final product), (b) must be declared by supplier to be "food-grade" as part of the COA, © IMEX, if the product is manufactured and distributed locally, it is often mandatory that an official registration/approval of the item exists ? (d) If imported, what equivalent documentation is available?

All this can be one HACCP prerequisite (supplier approval) if you wish (as defined in the original US / HACCP presentations I think).

It is also logical to obtain periodic validation of an ingredient composition although this is not always so easy IMEX. Similarly, although preferred, it is often difficult to audit non-local suppliers (unless you like travelling ), these are case-by-case situations.

Rgds / Charles.C

Trusting the supplier is the only thing i could do now as the company is not really ready to commit into sending the raw materials for analysis as part of validation.

We may assume that the suppliers are very strict and rule obeying and they did stringent analysis on their materials before selling it to us, hence the trusting in COA. But in my opinion doing the analysis is always the safest way out.

My bosses dont share the same thinking though.