STiR coffee and tea magazine

STiR coffee and tea 51 Time is up as the FDA steps up enforcement, leaving many importers unaware and vulner- able to stopped shipments, legal action and fines. - Joe DeRupo Filing can be done electronically using FDA's Unified Registration and List System (FURLs) beginning Oct. 1, 2018 (or by mailing FDA a completed Form 3942). The form will take half an hour to complete after first calculating annual sales and market value of all foods manufactured, packed, or held in the preceding three years to determine eligibility. This total includes any subsidiaries and affiliates. FDA asks for calculations and financial support- ing documents. The primary concerns is safety, says Spencer Turer, v.p. at Coffee Enterprises, a laboratory equipped to evaluate coffee quality and "determine when coffee is within specification and expec- tation and when it is not." He said FSMA's requirements for preventative controls "have increased the demand for analy- sis of pathogens such as E. coli, salmonella, staphylococcus, listeria (LPT), clostridium perfrin- gens, bacillus cereus; microbiological analysis (coliform, yeast, and mold, aerobic plate count, 5-day anaerobic plate count); pesticide analysis, and mycotoxin multi-screening (aflatoxins B1 B2 G1 G2, ochratoxin A, total fumonisin, T-2 toxin, HT-2 toxin, vomitoxin, and zearalenone. "Very often, a food safety or chemical analysis project is commissioned to answer a specific question or for an individual concern by the customer of our client," he said. Typical roaster controls include physical, sensory, and chemical analysis of green coffee prod- ucts prior to receiving them in their facility, using sorting and/or cleaning equipment for green coffee within process controls, and process controls with full lot traceability from purchase, through manufacturing to product sales. Turer says that "strong relationships and direct communications with the importer, farmer, and milling operation can increase chances of preventing unwanted contamination or quality de- terioration issues." "Roasters should coordinate with their importers regarding inspections and hazard analysis protection. Requesting quality control and analysis reports is suggested," he said. Tea blenders face similar challenges, complicated by the large number of spices, herbs, fruit, and floral inclusions. Last year FDA noted failure to comply with FSVP in 108 citations, it is probable that FSMA violations will increase significantly following the latest deadlines.

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