It would be hard to be too prescriptive without knowing a lot about your process or the materials involved. It sounds like your consultant is opting for increasing your testing to a lot-by-lot sort of scheme rather than monthly testing. Depending on your volume, monthly testing may not be frequent enough to be representative of all finished goods you release. Sure you get COAs on every lot, but what about risks introduced by your own handling of the raw material? (Blending equipment, packaging, staging, etc.) Even in low-risk foods, you should have some reasoning to support your decision for infrequent testing. Having a history of lot-by-lot testing showing that you make clean product is a good place to start. Once that is established you may be able to justifiably reduce testing frequency.
A justification for whether your testing is "enough" is typically based on a risk assessment of your particular product recipe, facility (environmental monitoring), processing method, intended use, and statistics. If you intend/expect customers to brew your tea cold, is that accounted for in your microbial specifications? What risks are present in this brewing method as opposed to boiling water, and how do you mitigate those risks? If your position is that your finished product is safe to consume as cold brew, you should have a suite of data/information to support that stance. Your consultant might be saying that your current justification is lacking and should be supported by more data. I'm not sure, however, what he means by getting "validation from every tea source" if you're already getting COAs.
Maybe some more conversations with your consultant are in order? Lipton has the resources to do whatever validation projects they'd like to to justify their product's safety. But there are plenty of smaller tea blenders that don't bear this sort of warning on their product either. So there must be some kind of reasonable direction your company could take to be compliant. Unfortunately I don't have experience with the industry so I don't know the norm.
Edited by Brothbro, 04 August 2023 - 06:59 PM.