Cider processors now have something in common with meat, poultry and seafood processors.They need todevelop and implement a Hazard Analysis Critical Control Point (HACCP) food safety plan.A new FDA regulation,which can be found http://www.cfsan.fda.gov/~comm/haccpjui.html, now requires that juice processors have a plan that helps identify critical food safety points in their process and provides the tools needed to keep their cider safe.
The date at which the regulation becomes effective depends on the size of the operation. Larger processors had to comply by January 22. Small businesses that employ fewer than 500 persons have until January 21, 2003.Very small businesses must comply by January 20, 2004 if they have either (1) total annual sales of less than $500,000; (2) total annual sales greater than $500,000 but total food sales less than $50,000; or (3) fewer than an average of 100 full-time employees and fewer than 100,000 containers produced for retail sale.
WHO IS COVERED UNDER THE HACCP RULE?
In general, if you sell your cider to another business (a wholesale distributor or retailer), the FDA considers you a processor, and you must operate under a HACCP plan. All processors, regardless of their operation’s size,must develop a HACCP plan and pasteurize by heat or an approved alternative process. In addition, processors must include a juice pasteurization treatment that will achieve a 5-log (99.999%) reduction in harmful pathogens.
However, the FDA has ruled that if you make cider from your own apples or apples that you have purchased and only sell it directly to consumers (e.g., roadside stands, farmers’ markets, internet sales), you are considered a retailer. Therefore, your cider does not need to be processed under a HACCP system.
SOME OTHER CONSIDERATIONS
• If you are a grower, and you send your apples to a central processing facility (i.e., dairy or juice processor), that processor must operate under a HACCP plan.You, as the grower, do not need a plan. However, attending a HACCP course will help you to understand how your cider is being monitored to insure its safety.You will be better informed and able to inform your customers about your product.
• If you hire another cider maker to make cider from your apples and you sell this cider at your roadside stand, it is the cider maker who must have a HACCP plan, not you.
• Retail cider producers are not covered by the regulation and not required to establish a HACCP system, regardless of whether they pasteurize their products.
WHAT ABOUT THE WARNING LABEL?
A cider processor who sells cider wholesale or to other retailers can no longer use a warning label. They must treat (pasteurize) the cider to achieve a 5-log reduction in harmful pathogens, such as E.coli O157:H7.
Retail operations that do not pasteurize must continue to label their packaged product with a warning statement that informs at-risk consumers of the hazards associated with untreated cider.
IF I AM ONLY RETAILING FROM MY OWN STAND, DO I NEED TO LEARN ABOUT HACCP?
It makes sense for all who process cider to take an HACCP training course and write a HACCP plan. HACCP helps you to focus on the safety of your cider. An outbreak caused by cider from your facility will have a negative impact on all cider processors when the newspapers, TV and radio stations tell everyone about it!
WHERE CAN I LEARNABOUT HACCP?
The University of Connecticut Cooperative Extension System will offer HACCP training courses as soon as the FDA materials are available.We would like to offer a course in late spring 2002. However,we need to wait until the FDA training program is established.As soon as dates are set,we will get the message out to cider makers. HACCP courses are typically 2 to 3 days long and provide you with the information you need to develop a plan specific to your operation and its needs.
For more information and to get your name on a mailing list, please call Diane Wright Hirsch, Extension Educator, (203) 407-3163.
This information is adapted from Pennsylvania Fruit Times, January 8, 2002. Vol.21,No.1.
Originally published in Yankee Grower Vol. 4 No. 2
