Bean-to-Bar Makers – What Testing is Necessary?
This question came to TCL via email and, rather than respond privately to the author, I thought the answers were worth sharing.
The Questions
Do you have an idea how many craft chocolate makers have their products tested for pathogens, molds, toxins, heavy metals, etc.? At one session at [a recent conference] some participants seemed to indicate they periodically test their chocolate batches and others always test a sample of each batch. ... I’m trying to figure out if there’s a standard our industry segment works to.
My Responses
Disclaimer: I am not a lawyer. Nor an insurance agent. This is based on my understanding of rules and regulations in the US and to a lesser extent in the EU, with not much detailed understanding of the regulations in Japan and other parts of the world. You should consult a lawyer with experience in these areas, and your insurance agency.
Duty
As a food manufacturer, you have a responsibility to your customers to manufacture products that are not likely to be injurious to their health, and to package and label those products in a manner that a) protects your products through the distribution chain to the consumer, and b) communicates clearly about possible risks in consuming the product (e.g., an allergen statement).
Failure to do so can lead to product recalls and, if serious or willful negligence can be found, fines or worse.
Risk
Obviously, the risks to large companies are greater than to small ones. Big companies risk serious reputational damage and they can be the targets of punitive class-action lawsuits (because they have the big bucks). Steps taken to ensure product safety, though they can be expensive, are probably less costly than reputational, legal, and financial consequences.
For small makers whose products are not in widespread distribution there is the tendency to seek to balance the cost of testing and equipment against the potential risk of someone getting sick and reporting the incident to the FDA. This is like playing Russian roulette – but without knowing how many of the chambers are loaded and with what.
Critical Control Points
Think about risk strategically and focus attention first on the areas with the highest risks of potential contamination.
SOPs. If you don’t have a manual of Standard Operating Procedures, you are going to be fighting an uphill battle should you ever run into a situation where one of your products gets reported. SOPs cover every aspect of every process – what to do when a new shipment of beans arrives; how new employees are trained on processes, how inspections are done, how to clean equipment. Even how SOPs are created and approved and changed and what happens to deprecated SOPs. These can be a solid starting point for a formal HACCP program.
I helped a consulting client – in Central America, on a coastal island – with their SOPs. The daily opening SOP included a) sweeping and mopping where the machines would be used (they were moved at night to clean under) to check for insects and dirt/dust before the machines were pushed back into place, and checking the weather forecast to anticipate how changes in humidity might affect temper, among other tasks. There was a daily log (specified in the SOP) that described each step and required the person opening up to check a box or write their observations.
Beans. You should require a Certificate of Analysis (CoA or CofA – aka phytosanitary certificate) from your bean supplier for each shipment of beans you receive. There should be what is referred to as a “plate count” that reveals levels of yeasts, spores, and organisms such as salmonella and e coli. There should also be a screen for aflatoxins and ochratoxins, which though less common tend to accumulate in the body. Finally, given EU and California regulations you want to screen for heavy metals, especially cadmium and lead.
This is an important aspect of compliance with the Food Safety Modernization Act (FSMA). As a food manufacturer you need to be able to trace your beans (actually, all your ingredients) to their point of origin and provide acceptable supporting documentation if asked.
You may also want to perform independent laboratory analysis of beans, in addition to visual inspection. (Have an SOP covering how and when.) Very expensive when you’re buying a bag at a time – cheap peace of mind when purchasing beans by the pallet. This should be incorporated as a part of the acceptance process (SOP, again) for each new shipment.
It’s also important to be up on FDA regulations and requirements with respect to registering your business as a food manufacturer and, for companies handling cocoa beans, what the FDA requires with respect to testing every shipment of beans.
Example :: FDA inspectors showing up at your chocolate factory expect there to be a magnetic trap used in the bean inspection process. Almost no small maker has one. The FDA has the right to shut you down if you don’t.
This is not comprehensive coverage of the topic of beans. For example, you want to make sure that you know how to store your beans properly to guard against cocoa moth infestation and more – and have SOPs that cover these topics.
Testing. Some companies test every batch. This is expensive and time consuming when a batch is 35kg or less and far less onerous when batches are much larger.
If you decide not to test every batch (for whatever reasons), you may wish to adopt a “conservative proactive” strategy.
An example of this might be to perform a test on the beans and the roasted and cracked/winnowed nibs to verify the CofA for key concerns; yeasts and mold, salmonella, e coli, afla- and ochratoxins, and heavy metals. Roasting is not going to affect heavy metals, but you will see what effect your roasting profile has on the biologicals.
In addition, you should probably want to perform a test on the first batch of chocolate produced from those nibs. This test would include a nutrition analysis and tests for all common allergens. If everything is okay and your general hygiene standards are high and consistently applied (SOP) then you should consult legal/insurance and ask about their level of confidence with this approach.
There are separate, additional, concerns if you are using inclusions.
I have personally received a recently-made (less than 30 days after date of manufacture) craft chocolate bar with cashews on the back (not mixed into the chocolate) that was already moldy. I did not eat any of the chocolate, but it was probably not the chocolate that was the culprit. Poor storage of the cashews before use and – a likely contributing factor – loose foil wrap and paper overwrap chosen for its prettiness, not its oxygen/moisture barrier properties.
And, finally, you may consider having your equipment and your facility tested on a regular basis – many testing labs can provide sample kits. This might reveal a source of contamination that might not be what you think it is.
Conclusions
Testing is a very complex topic and how you respond to it depends upon your business and your appetite for risk.
Resources – Food Testing Labs
The mention of a lab in the following list is not a recommendation. This is a list of labs culled from a much longer list returned when searching “food testing labs” using a search engine. Some offer services in the US only, some are international.
Labs are listed alphabetically – no inference should be made by the order of appearance. The sites themselves respond differently to the request for a visual “bookmark” and there is nothing I can do about that. Some do not provide any usable resource at all and so are represented just with a link.
RL Food Testing Laboratory
Listing image credit: ThisisEngineering RAEng on Unsplash
What are your thoughts on testing? If you are a bean-to-bar chocolate maker we are especially interested in hearing your experiences with testing and how you approached answering this question. Let everyone know in the comments.