The guidance note, ‘Good Manufacturing Practices for the Production of Ready-to-eat Unpasteurised Fermented Plant-based Products’ addresses systemic non-compliance with EU and Irish food law identified in an FSAI survey and informs the industry on how best to conform with legal requirements.
Developed in consultation with industry stakeholders, the guide targets any food business supplying fermented plant-based products to the Irish market, such as tea kombucha, kefir and ginger soda.
The safety of unpasteurised fermented products relies primarily on the good hygienic status of the starting plant material, appropriate storage, and handling conditions, however variations in production methods and ingredients used has resulted in inconsistent product content and quality, the guide says.
FSAI Chief Executive, Dr Pamela Byrne said the guidance should help producers achieve consistent production methods and improve safety standards in the storage, handling, and transportation of fermented beverages. “It also provides guidance about the labelling requirements for prepacked fermented products.”
Food safety and non-compliance
Fermented foods can pose the same safety and spoilage risks associated with other foods containing physical, chemical, and biological hazards, the FSAI guide says, and “sub-optimal production, storage and handling conditions can compromise the safety and quality of products”.
While all food producers should follow basic principles of good manufacturing practices (GMPs) and good hygienic practices (GHPs) and comply with the hazard analysis and critical control point (HACCP) as part of a food safety management system, standards and degree of conformity can vary.
The FSAI survey sought to determine the degree of regulatory compliance as a result of the accelerated growth in unpasteurised fermented products in recent years – and uncovered troubling regulatory non-compliance issues.
Absence of alcohol labelling
Problems in labelling for alcohol content were a particular cause for concern.
When analysed, four (13%) items out of 32 were found to contain undeclared alcohol content at 1.5-3.9%. This is significant finding, the authors explained, given that many beers sold in Ireland contain 4.5% alcohol.
In addition, EU labelling rules require producers to declare alcohol content of food products containing more than 1.2% alcohol by volume ‘to inform consumer choice’ (Food Information to Consumers (FIC) Regulation (EU) No 1169/2011).
The survey authors wrote that misleading information could have serious implications for vulnerable consumers (such as pregnant or breastfeeding women, and people with underlying health conditions) who may unwittingly consume alcohol, or where low-level alcohol consumption is not permitted at work and can impair performance.
Fermented plant-based products can be difficult to manage, Dr Byrne confirmed: “Under certain conditions residual fermentation can continue during handling and storage leading to an accumulation of alcohol to significant levels. The inadvertent consumption of alcohol (up to 3.9% according to the survey) could pose adverse health issues for vulnerable consumers like pregnant or breastfeeding women.”
There are also “obvious consequences too for those employed in professions where there are restricted levels of alcohol permitted such as certain categories of licensed vehicle drivers, machine operators and airline pilots,” she said.
Samples were collected by environmental health officers from the Health Service Executive (HSE) and analysed by the Public Analyst’s Laboratory in Cork (CPAL).
Survey results also revealed that 29 (91%) products contained unauthorised nutrition and/or health claims, such as ‘contains live cultures’ and ‘full of goodness’ in; 24 (75%) were missing general labelling information including mandatory label information, such as name and address of product, nutrition table, use by date and list of ingredients, and 18 (56%) contained inappropriate labelling storage instructions (‘best served chilled’ and ‘keep refrigerated after opening’, for example).