Validation study from nuts supplier

Hey guys!

So we are trying to source some nuts from a supplier. (Roasted mainly)

So we asked them to supply us with COAs for every lot shipped to us but they went ahead and sent us their roaster validations.

While that is great and important, I feel they still need to send us COAs for every lot they ship to us? 

Has anyone dealt with this before? Is that validation study sufficient that we don't need any COAs? I have mixed feelings. I feel it's sufficient but not sufficient at the same time.

Help :)

I would still request COA for each lot as a proof of product quality, safety and legality. Otherwise, it would be necessary to test ingredient yourself. 

I would still want thw coa's

Pftt... they just replied saying they "can't do COAs" ...

Pftt... they just replied saying they "can't do COAs" ...

 

Yes, that's what it usually means. Can't or Won't.

Suspicious... It's just like we tried to purchase organic honey from Amish community: when I tried to reach them out to get some doc's, I could only get old-old lady's voice on the phone saying "I have no idea what you're talking about!" On one hand - product is definitely organic due to their believes and specifics, on the other - no proof:) Sorry for off-topic

Hey guys!

 

So we are trying to source some nuts from a supplier. (Roasted mainly)

 

So we asked them to supply us with COAs for every lot shipped to us but they went ahead and sent us their roaster validations.

 

While that is great and important, I feel they still need to send us COAs for every lot they ship to us? 

 

Has anyone dealt with this before? Is that validation study sufficient that we don't need any COAs? I have mixed feelings. I feel it's sufficient but not sufficient at the same time.

 

Help :)

I've dealt with this as well recently. Our issue was the companies environmental monitoring program. It wasn't sufficient enough.

Suspicious... It's just like we tried to purchase organic honey from Amish community: when I tried to reach them out to get some doc's, I could only get old-old lady's voice on the phone saying "I have no idea what you're talking about!" On one hand - product is definitely organic due to their believes and specifics, on the other - no proof:) Sorry for off-topic

Okay that's fishy..... I mean claiming they are organic with no proof... yikes.

I worked at a similar company a while back. Roasting nuts and I can't remember if we tested finished products... we did have roaster validations yes.. but I can't seem to remember if we generated COAs for the roasted product. It was SQF and had major customers like Disney and Universal Studios. So I am just thinking that probably the Validation is sufficient? 

Certificate of Analysis reflects physical, chemical and biological properties of a product as a proof of food safety, quality and legality and compliance to regulatory requirements and product specification. Roasted nuts are quite simple product and don't seem to require much testing, but what if, for instance, those nuts were stored under improper condition and got moldy? Or, say, contaminated with some other allergen - but you, from your end, would claim your product containing only nuts. 

Certificate of Analysis reflects physical, chemical and biological properties of a product as a proof of food safety, quality and legality and compliance to regulatory requirements and product specification. Roasted nuts are quite simple product and don't seem to require much testing, but what if, for instance, those nuts were stored under improper condition and got moldy? Or, say, contaminated with some other allergen - but you, from your end, would claim your product containing only nuts. 

I agree. But I mean that is a risk for most products we buy. How can we be sure about storage conditions even when they are GFSI certified? We check for those things upon arrival and the suppliers outline this in their plans. I guess that is a way to assure that. Also yes we have a warning statement for all allergens on our labels. Because we store them in allergen areas. 

They replied to us saying "we don’t do COA on roasted peanuts our roasted are certified with .5 kill log". 

Of course the CoA can always "vary" with the sampling. Usually in a nice way.

 

 

They replied to us saying "we don’t do COA on roasted peanuts our roasted are certified with .5 kill log". 

THere is no legal requirement to do testing on every lot, so this company has decided not to. Thus you would normally get a one time "certificate of conformance" stating the process they go through.

Up to your own risk assessment if that is sufficient of if you require lot-by-lot data. Be aware that demanding CoA's where none existed is also a great way to get fabricated CoA's.

Validation study won't show you other testing such as aflatoxin. Ask for COA for each lot or at another Defined frequency if you are confident they are doing all the testing required.

I used to work at a nut roasting facility and we did not perform product testing. We had a 5 log reduction kill step for Salmonella on our roasters which we provided to customers. If customers demanded COA's, we would typically provide them with the raw nut COA's from our suppliers in addition to our validation and other HACCP material.

We did test one product and it was raw peanuts since the supplier provided only aflatoxin testing. We would sample and test raw peanuts for Salmonella so we would also send that to our customers if requested. 

Maybe try asking for the raw nut COA's and see if they can provide it. 

As a tree nut processor we will always provide COA (at cost of course) when customers requires it, and a cert of pasteurization even if a COA is not.  If a customer doesn't have a spec sheet for their particular item we have the micro lab test to our own internal specifications.  

I agree in having a COA in hand either prior to or at time of delivery. If your supplier does not provide micro, chem, or quality testing or work with a third party qualified lab then perhaps you can hire a lab to sample the lot prior to shipping and ask that the lot to be held until you have results this approach allows you to test for what you want on the COA if they are being resistant. 

In the future perhaps spelling out COA requirements on a contract or PO may help.

Best of luck!

Validation study won't show you other testing such as aflatoxin. Ask for COA for each lot or at another Defined frequency if you are confident they are doing all the testing required.

Exactly, my issue is Aflatoxins. 

Certain studies have shown they are not entirely killed by the roasting process. I will be testing for Aflatoxins randomly myself when we get their products. Only way to verify! 

Hi,

do you receive the full validation study report?
I have been several times on audits for nuts and I have seen many "validations" - some very good, some less and more or less unsuitable.
Nevertheless sampling is most important in nuts/nuts paste (-> e.g. Salmonella).

For me I accept a CoA only if I have accepeted the process of roasting incl. validiation and the sampling procedure before. No discussion.

If you are looking for literaturehave a look what the California Almond Board provides - very helpful.

[I have been working before in pharmaceutical and medical device industry (-> implants). In medical device the sterilization method by radiation is accepted without CoA. In the registration you have to provide process information and validation study (-> acc. standard). Only in this case I know validation w/o CoA]

Rgds

moskito

Would you be ok with a CoC? If so, that's probably doable by them, especially if they've already done roaster validations. Periodic CoA's, CoC on each lot, and your own random verification checks might be a good way to minimize the risk. I have no experience in the nut industry aside from almost taking a QC director position in a pecan distributor, and for the life of me I can't remember if they did CoA's or CoC's.

I am going through a similar CoA vs CoC 'discussion' where I work currently, which is what made me think to suggest this. It's been a tough nut to crack.

It is up to you and your level in confidence with the supplier. Have you audited them?

We test every lot (pecans) prior to use or shipment, so it is not unheard of. I assume its a cost they aren't willing to incur. Validation is great but its only a snapshot of a controlled test so it doesn't guarantee the load you receive today is free of pathogens or aflatoxin. Do you do testing on your final product? If so, that may give you a little more comfort level in accepting the product without a COA. 

In my view COA's are really pointless, honestly.  Who is going to send you a COA if the parameters are out of spec?  It's all fine and dandy to check the box or cover your butt from a legal standpoint, but beyond this...worthless.

If you have a critical ingredient that must meet a certain specification you should be testing for it.  If it isn't critical then a letter of guarantee should suffice; this whole COA business has really gotten out of hand...but we must tow the line so here we are...

The Food Scientist, I recommend telling the supplier what you need on the COA.  If they can't meet what you need then find another supplier.  If the upper management of the company doesn't want to use another supplier then you are stuck, but let them know you have to do additional testing on the ingredient which takes time and money, possibly tying up the ingredient until all testing passes and is in your compliance.

In my view COA's are really pointless, honestly.  Who is going to send you a COA if the parameters are out of spec?  It's all fine and dandy to check the box or cover your butt from a legal standpoint, but beyond this...worthless.

 

If you have a critical ingredient that must meet a certain specification you should be testing for it.  If it isn't critical then a letter of guarantee should suffice; this whole COA business has really gotten out of hand...but we must tow the line so here we are...

 

The Food Scientist, I recommend telling the supplier what you need on the COA.  If they can't meet what you need then find another supplier.  If the upper management of the company doesn't want to use another supplier then you are stuck, but let them know you have to do additional testing on the ingredient which takes time and money, possibly tying up the ingredient until all testing passes and is in your compliance.

Well, it's quite frustrating to find out people think so: I'm personally responsible for COAs I'm issuing basing on micro testing results. So, COAs are given to only products within the spec, which fact provides the assurance to the customers that my company supplies safe products. I don't agree: COAs are not worthless.

Well, it's quite frustrating to find out people think so: I'm personally responsible for COAs I'm issuing basing on micro testing results. So, COAs are given to only products within the spec, which fact provides the assurance to the customers that my company supplies safe products. I don't agree: COAs are not worthless.

Ryan M. - OK, let's suppose we stop sending our products for micro testing as we're absolutely sure our programs work perfectly and we're safe to sell our products without testing. What do I say to our customers requesting COAs (most of our customers do that)? Make the COAs up?

I am not advocating anything regarding your customers.  We are now in a time where everyone expects a COA for everything, even if they don't know why they need a COA or what they are specifically looking for on the COA.  It is CYA mode for everyone, which is understandable in this age of lawsuits and litigation.

What I'm communicating is from the receiver of the materials.  Do not assume the materials meet the specifications on the COA.  From this point of view, in my 20 plus years experience, COA's are pointless.  I have come across far too many material supply issues where I had a COA in hand showing everything was within specification.

So, if you are a supplier to a customer requesting a COA you have to determine what works for you and the customers.  I've had customers who are fine with a CoC (Certificate of Conformance) or a Letter of Guarantee.  Typically, these are customers that do more testing in-house of the materials before receiving, or with pre-ship samples sent to them.  I've also had customers who tell me they will not receive material without a COA in hand, but they don't know what they need on the COA; it just has to be a COA.  Fine...these customer get something that says "within specification" on a few different things of the material.  It does depend on the type of material you supply, and the "critical nature" of the material.  I haven't had much success in convincing customers COA's are unnecessary, but I've had some good conversations about them where customers do more of their own testing in house, or they find out, "Hey I need to be testing for this and I didn't even know."

Ryan M. - OK, let's suppose we stop sending our products for micro testing as we're absolutely sure our programs work perfectly and we're safe to sell our products without testing. What do I say to our customers requesting COAs (most of our customers do that)? Make the COAs up?