What are the Food Safety Concerns for Green Coffee?
There is a lot of confusion and misinformation about food safety and coffee, and food safety and specialty coffee. Since May this year roasters in the USA need to have a food safety system in place in order to be in compliance with FSMA. The EU, which has had quite a strong food safety system in place for a long time, also has started checking coffee roasters more and more the last couple of years. Where specialty roasters, especially smaller ones, have been able to fly under the radar, they are now being asked to proof their product is safe to consume.
Today I will talk a little on the cycle of HACCP, talk mostly about risks in green coffee, and a little about risks of roasted coffee. I'm not going to get into details of FSMA, but instead will try to provide understanding of the risks your food safety authority is worried about when they come into your roastery.
What is Food Safety?
To start with; food safety; what is it? Food safety is about health of consumers. It is about the person who is actually drinking your coffee. So basically; can this product kill you, give you cancer, make you sick in any other way, or make you nauseous?
Generally speaking coffee is quite a safe product. There is a 'killing' step; roasting -I know it hurts to think of it like this, my apologies, it's food safety speak- which kills off many risks, such as salmonella amongst others. Plus, you grind it, you brew it with hot water and most of the time you put it through a filter before serving it. In other words, chances are quite low that something harmful is still in the cup.
But there are still some risks you need to consider, if you want to get through a food safety audit without any bumps and scratches.
To give an example. I am often contacted by roasters to ask if we provide any test results for OTA, a toxin which can often be found in coffee. Often it's asked in a very blasé way, like, "this dude came by from the government asking if our coffees are free of OTA, obviously this guy does not know what he is talking about, but I guess that we need it or something". To which I reply that, actually there is a government set limit of OTA on roasted coffee in most countries. So, yes, you need to be able to say if your coffee is within these limits.
The thing is, most governments don't make a distinction between commodity coffee and specialty coffee. So if there is a risk for something nasty in commodity coffee, then you, as a specialty roaster, need to proof that your product is safe. Additionally, what we see as specialty coffee if defined very narrowly as scoring above 80 on the cupping table, might actually not be as safe as you think. I have had an 85 scoring coffee test positive for OTA before. And that is a problem. Sometimes we think specialty coffee is safe, but it might not be. Your convincing the auditor super powers needs some more meat on it's bones.
So what do you need to do?
Most roasters and coffeebars will have a HACCP system. What you need to do is integrate your green coffee and your roasting and roasted coffee into your HACCP system. Now, just like your other products you can push the responsibility for the green coffee backwards in the chain; to your trader or your coffee producer.
But you need to remember that the roaster or coffeebar, as the one actually selling to the consumer, is responsible for making sure your trader or producer are delivering you a safe product. Most bigger roasters will have a supplier approval system in place for example, to ensure that their supplier is up to scratch in this subject.
1. Analyse your Hazards
So what can you ask of your supplier, be it a trader or producer? What should you look out for?
A HACCP system consists of a never ending cycle. The best thing is to create a flowchart from bean to cup and analyse what risks, or hazards you have during what step in the processing. And what in the processing limits these hazards.
The standard hazards to look into are: microbiology, chemicals, allergens and physical.
Microbiology for coffee is usually OTA, or ochratoxin A, which is a toxin. It is a carcinogen and has a negative influence on your brain and your immune system. OTA can occur anywhere in the chain. You can think about cherries which are picked when they are overripe, dried in layers which are too thick, rain during drying, stored in a wet environment, and so on. Often the moisture level will be too high, but this is not a given. Often the wateractivity will be too high.
Black beans, sour beans, mouldy beans, and an earthy taste can be an indication that your coffee might be infected with OTA. But the only way knowing for sure, is testing in a lab.
Now roasting will get rid of a percentage of OTA, but there can still be traces in your roasted coffee.
What is important to know is that there is no OTA limit on green coffee, only on roasted coffee. Which means that if your supplier can provide you information on OTA levels on the coffee you buy from them, this is a bonus. They are not obliged to have this information.
Chemical risk is when there are chemicals in your coffee bean. Now, for conventional coffees this risk is quite low, although not non-existent. But if you have organic coffees, where you promise that your coffee does not contain any pesticide residues, you might be asked to proof this. I will not step into the discussion whether pesticides are bad for your health or not. But what you do have to ask yourself is: how can I guarantee my organic coffee is not contaminated with pesticides?
Has the producer not used pesticides? Is there enough space between the producer and their neighbours, whom might be using pesticides? Did the trader, shipper and warehouse keep my organic coffee separate from conventional products? Sorry to burst your bubble, but contamination might have taken place. Your supplier should have this sorted, should be able to give you the information you need for your audit and possibly give you certificates of analysis for chemical residues on the coffees you buy from them, guaranteeing a product free from contamination, up till the point where ownership changes to you.
Talking about chemicals, let's discuss packaging and mineral oils. A lot of oils are bad for you, for your liver and lymph nodes. If you have your coffee in only jute bags, in stead of grainpro for example, your jute bags need to be free of hydrocarbons. Often an oil is used to soften the jute fibres before spinning and these oils are not good for you.
There are already regulations in place that regulate for this mineral oil. But these are not the only oils to be concerned about. Recently MOSH, MOAH and POSH have been making the rounds in food safety land. Again packaging is important; are there no ink used made of mineral oils that can contaminate your coffee? Is your packaging made to form a real barrier between your coffee and mineral oils that want to seep in? But also pertaining to oils that might have come into contact with your coffee during production. For example, was your coffee dried on the road by a smallholder, and perhaps a car leaked oil onto it?
Mineral oils are heat resistant. So even if you roast the coffee, there is still a risk that mineral oils in your batch can affect the health of your customer. The good thing? There are no regulations yet on mineral oils, other than jute packaging. However, most people working in food safety are venturing a guess this won't take long.
You can ask your supplier for a migration report or a statement that the packaging used is safe and is food grade appropriate.
Allergens and Physical Hazards
Then...allergens. Does your producer, shipper or warehouse keep your coffee separate from allergens? For coffee the most common risks are corn and nuts. Often you will catch them after roasting though, and a grade one, specialty coffee really should not have any. You can ask for risk of contamination of your supplier. And check that your supplier has sieves, belts, infrared, x-rays, et cetera in place to take out any contaminates that are considered allergens.
The same can be said for physical, which is basically anything that does not belong and can harm your customer. Again, the risk of this is low for coffee, because of the grinding and filtering. But how do you make sure there are no pieces of metal, hard plastic or glass in your coffee?
Your supplier should be able to give some background on this as well. If you ask a product specification, which will also contain declarations on grade, toxins, and chemicals, there will also be statements on there pertaining to allergens and occasionally physical hazards. However, as mentioned physical hazards are often a very low risk in coffee, because of the steps necessary for brewing.
Most things mentioned above you can move backwards to your supplier and avoid the headache. However as a roaster, you might have some additional hazards to consider. Like acrylamide, which can develop during roasting. And of course physical things can also fall into the beans in your roastery or bar as well, think of glass lamps above your roaster. Or perhaps you flush your coffee bags with gas before sealing. Are you doing this safely?
Once you have an overview of these risks. How are you preventing them? You can add certain preventions in your flowchart, such as sieves, belts, x-rays, and infrared systems are creating a lower risk of physical hazards at the huller. Or adding grinding and filtering at the bar as a prevention of physical hazards.
Or the fact that you have a green grading report showing that you have zero primary defects, might give you some leeway on risks of OTA. Some of you might be able to argue that you are not at risk for acrylamide, because of your roast profile, based on literature. But others you will just have to check. So you need to set up a system to check these things. How often are you checking what, how? And what are the results?
The most important thing? Have it written down in your HACCP plan, whether you have written down why you are not at risk or how you are checking and/or preventing this risk yourself.
This the third thing you will have to do, after analysing your hazards and setting up your preventive controls: monitoring. If you did not write it down, it did not happen.
Here you might want to add a recall plan, or a system which blocks certain batches until you've tested them. Because what is worse than testing a batch for OTA, only to get a positive result, but then already having sold these coffees to consumers? Scary times...
4. Control and Revert Back
Then, finally, when you think you are all done. You have a little longer way to go: control. Every year you should consider: did my preventive controls work? Did I have any issues or complaints? Did literature add any hazards that I had not thought about? Did I have any concerns about food safety issues with my suppliers, or did they deliver me safe produce?
And if necessary, you need to create a corrective action plan, and write that down. And implement it into your hazard analysis, your prevention and your monitoring. After which you need to verify through extra testing, that your corrective action actually worked. And all of this needs to be recorded, to guarantee its success. And to show it to your auditor.
And then you start back at the top again...