Food Safety News reported that the juice company Bamboo Juice received quite the scolding from the Food and Drug Administration (FDA). Included in their strongly worded letter was a list of violations, such as:
- misbranded food (calling a juice “spinach apple” when it also includes other ingredients)
- unapproved new drugs (claiming a juice is an “inflammation tamer” or is a “natural remedy for kicking colds and clearing sinuses”)
- inadequate 5-log reduction plan (not enough steps taken to eliminate microbial hazards)
While the first two are more about phrasing choices, the last item may cause harm to consumers. A 5-log reduction plan should be included in the Hazard Analysis Critical Control Point (HACCP) plan, which is a collection of procedures that the business implements in order to prevent outbreaks of food illnesses.
While it was initially required for seafood and meat manufacturers, HACCP plans are now a requirement for almost every aspect of the food manufacturing industry. So what does that mean for juice?
HACCP and Pasteurization
When I worked for a different Georgia juice company, one of my first tasks was to create the HACCP plan.
In addition to Good Manufacturing Practices (GMPs) and Sanitary Standard Operating Procedures (SSOPs), the 5-Log Reduction is a major component of food illness prevention. For those who are not food safety or math savvy, a 5-Log Reduction refers to what steps the business takes to reduce the number of microorganisms (read: bad bacteria) in their final product.
Until recently, that usually meant pasteurization, which is the process of heating up the product in order to kill bad bacteria. As a result, however, the flavor may change and some of the nutritional value may decrease.
But with high pressure pasteurization (HPP), the bad bacteria is eliminated through a cold pressure process, therefore preserving the nutrients and flavor while still eliminating the bad bacteria.
But there are many who believe that pasteurization isn’t entirely necessary. Think about it: do you wash your apple in water that’s 160° F for six seconds before eating it? If you juiced that apple instead, why would you heat it up to that same temperature for that same time period?
This example, of course, is not to scale. Juice companies receive huge quantities of produce from a variety of suppliers. It is, however, something to consider when you read about the dangers of drinking fresh juice.
Overall, pasteurizing juice is one of the best and most common ways to prevent food borne illnesses – a “better safe than sorry” situation. Its primary purpose is to prevent the highest risk microorganism, which in most cases is E. coli, clostridium botulinum (botulism), and salmonella.
But there are other steps businesses can (and do) take to prevent the occurrence of bad bacteria: properly washing the produce, culling for “bad apples,” and having good relationships with produce suppliers. That trust of sources can be crucial.
With the establishment of GMPs and SSOPs, some juice companies have two lines of juice:
- A fresh juice line, which is only sold directly to customers in retail locations
- A pasteurized juice line, which is only sold to consumers via a retailer such as Whole Foods, Publix, and other local markets
By having two product lines, a juice company can increase its business while also staying true to their mission of spreading good health.
Bamboo Juice and the FDA
According to this letter from the FDA, it seems that Bamboo Juice may not have two separate product lines, even though they sell juice both directly to consumers as well as through third parties.
The letter specifically states:
while your plan includes three critical control points as processing, bottling and cooler packaging and delivery temperatures, none of the critical control points identify and/or include a microbial reduction step. In addition, your “5-log reduction program”, attached to your HACCP plan, indicates the juice is not subject to any treatment that would ensure a 5 log reduction and is therefore not a suitable process to comply with the minimum 5 log reduction requirement for any of your juices.
While there are no details as to what “processing” includes, I read this statement as saying “you’re not pasteurizing your juices to prevent microbial growth.”
Bamboo Juices has made a commitment to not pasteurizing in order to preserve their products’ nutrients. This means, however, that they are not permitted to sell their juices to third party retailers.
I do not know whether Bamboo Juice has considered HPP as an alternative to traditional pasteurization. Because HPP is a newer technology, the financial barrier to access it is high – possibly higher than Bamboo Juice is willing to invest.
Hopefully, however, Bamboo Juice will find a way to meet FDA requirements while still producing the healthiest juice they can.
I love to simplify concepts so that customers can make informed decisions. Need help with that? Let’s talk.