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Growing the operation

What you have to write down

Updated

On this page5

More records than most food crafts, because two thresholds have to be evidenced and one of them is evidenced after the product has left.

Four record sets

Batch records, one per batch.

Raw material records: supplier, lot, specification, certificate of analysis.

Monitoring records, if you operate under HACCP, for every critical control point on every batch.

The threshold file, which is specific to this property.

The batch record

Batch code and date. Every raw material with its lot. Water treatment. Extraction time and temperature. Starting and finishing Brix and pH. Fermentation start, temperature and duration, where relevant. Treatment time and temperature, where relevant. Carbonation. Fill level and fill weight. Units filled, rejected and where they went.

The batch code goes on the bottle, or none of this connects to a product in somebody's hand.

The threshold file

The one that answers a regulator.

For the juice line: your exemption basis or your HACCP plan, the validation of the 5-log step, and the monitoring records that show it was achieved batch by batch.

For the alcohol line: the laboratory results on warm retained samples at end of shelf life, with the method, the laboratory, the sample storage conditions and the date.

That second one is the evidence that your product stays under 0.5 percent rather than starts under it, and it is the thing nobody has when they are asked.

Plus the pressure results from the same retains.

The retrieval test

Take a bottle with a code on it. How long to produce the batch record, the lots, the process figures, the treatment monitoring, the alcohol result for that formula and the list of who received the batch?

Under an hour is a working system. Run it on a quiet afternoon rather than on the day it matters.

References

21 CFR Part 120, Hazard Analysis and Critical Control Point (HACCP) Systems for juice. Covered processors must achieve a 5-log reduction in the pertinent pathogen. ecfr.gov
US Food and Drug Administration. Juice HACCP Hazards and Controls Guidance. How the 5-log requirement is met, validated and monitored. fda.gov
Alcohol and Tobacco Tax and Trade Bureau. Kombucha. Kombucha at 0.5 percent alcohol by volume or more, at any time during production, when bottled, or at any time after bottling as a result of continued fermentation, is an alcohol beverage subject to TTB regulation. ttb.gov
Written from the federal regulation and agency guidance named on each page, not from a laboratory. Whether a particular product meets a pathogen reduction requirement, and what its alcohol content actually is, are measurements about your product, and this is not those measurements.