Microbial testing requirements RTE products

Hello every one,


My company produces maple syrup, i guess it will fall into low acid RTE product. I am not sure about FDA requirments for this product. I have heard in past that if RTE products produced in usa, microbial analysis of product is mandetory. Is that the case? If yes please let me know where can i find this requirment.... we do analyze sample for microbial population but not all of them......


Thanks
Dave

Dear Dave,

I don’t know about USA regulatory requirements but, based on yr post, I sure hope you are not yet marketing this product.

How about yr (proposed) customer(s) ? No documentation required ?

Rgds / Charles.C

No till date customer has not given any specification.....

Dear Dave,

I don't know what your process or finished product specifications are therefore the following links may or may not be useful.

I wasn't able to find confirmation that RTE in USA requires mandatory micro testing but here there is a FDA link (para. 8) explaining risks associated with the product.

In case the Aw is higher than 0.85 and/or pH higher than 4.6 these FDA regs may apply: CFR Title 21 Part 108.35 and 113, additional details here

On this link there are some considerations about the product's microbiology. Due to the low Aw the main focus seems to be on yeasts, molds with some consideration given to sporeforming microorganisms in lower sugar alternatives (ref. also FDA para 8).

The links below are from Canadian Ministry of agriculture.
Food Safety Practices for the Production of Maple Syrup
Food Safety Practices for the Production of Maple Syrup2


Regards
Marco

Hi Marco,

Thanks for the links you provided. Actually we do not thermally process the syrup. Our basic process is to mix corn syrup, water, flavor and few preservative compounds in big mixing tank. After that it goes to packaging.

Dave

Dear Dave,

You might try checking out the Compendium of Methods for the Microbiological Examination of Foods and Microorganisms in Food 6 (published by the ICMSF). I frequently reference these books to determine what pathogens and spoilage organisms are a concern when our company is working with a new ingredient or product.

Hope this helps.

Cordially,
Jennifer

Hi Jennifer,

I have seen ICMSF. My concern is that i am working in small company where we do not have huge resources. So we do not check each lot for zero tolerance pathogens. If it is mandatory than i can go ahead and start doing that on each lot.

Dave

Dear Dave,

Perhaps it is easier to rephrase the options.?

One can assume (worst case scenario ? ) that a product put into retail availability will be eventually tested by "authorities".

If, for example, Salmonella is found, i think it is highly unlikely, except perhaps in a few well-defined cases, that the "authorities" will accept the result. This consequence is quite possibly regardless of a HACCP interpretation.

So, in addition to what might be called a moral obligation to the consumer, there is a probable (probability?) legalistic reason to test also. And, again from a worst case scenario, one should include the possible economic fall-out of a product recall / rejection.

I can understand the interest to determine if the product involved is one of the "well-defined" cases mentioned above. It seems rather unlikely to me but really should not be that difficult to determine IMO.

Rgds / Charles.C