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pabloqa

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Posted 31 May 2024 - 05:08 PM

Good morning!

I hope all is well.

I am looking for advice, at our company, we currently purchase organic honey and receive a COA with the following tests:

  • Organoleptic analysis.
  • Nitroimidazoles by LC-MS/MS.
  • Fructose/glucose ratio by HPLC-RI.
  • Chloramphenicol by LC-MS/MS.
  • Tetracyclines by LC-MS/MS.
  • Streptomycin by LC-MS/MS.
  • Nitrofurane metabolites by LC-MS/MS.
  • Sulfonamides and trimethoprim by LC-MS/MS.
  • Pesticides by GC and LC-MS.

FDA considers "Drug Residue" and "Pesticides" as potential hazards within their Draft Guidance for Hazard Analysis, so I was wondering if someone could let me know if any of the previous tests wouldn't be actually necessary to comply with regulations, and if there's any additional testing we should request, according to your experience and knowledge.

Besides drug residue tests and pesticides, we will continue to request sensory analysis and authenticity tests.

In addition, can you recommend any certified labs based in the US to send samples for testing?

Looking forward to your feedback or any comments!

Best regards,

Pablo.



SQFconsultant

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Posted 31 May 2024 - 07:43 PM

Does your supplier of the ORGANIC honey have a non-gmo and/or Organic certification???


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kingstudruler1

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Posted 31 May 2024 - 07:48 PM

Those seem reasonable to me.  I would think that because its certifed organic your risk of drugs and pesticides are much lower.   

 

To comply with the regulations you need to show that the you assesssed the risk and it is controlled.   Have you determined that the the risk is high enough to warrant a control?  The supplier should be controlling the risk.  At least that how im guessing you have tackled this issue (supply chain control).  Any testing done is is a another form of verification that the risk is controlled.   

 

There is a bunch of food labs out there that can do the testing.  Merieux, euofins, midwest, etc.   It might be advantegous to find someone local as well.   


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pabloqa

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Posted 03 June 2024 - 12:53 AM

Thank you very much for your reply!

Yes, actually our intention is to verify risks are controlled, as this is a new supplier.

I appreciate your feedback!

Best regards,

Pablo.
 

Those seem reasonable to me.  I would think that because its certifed organic your risk of drugs and pesticides are much lower.   

 

To comply with the regulations you need to show that the you assesssed the risk and it is controlled.   Have you determined that the the risk is high enough to warrant a control?  The supplier should be controlling the risk.  At least that how im guessing you have tackled this issue (supply chain control).  Any testing done is is a another form of verification that the risk is controlled.   

 

There is a bunch of food labs out there that can do the testing.  Merieux, euofins, midwest, etc.   It might be advantegous to find someone local as well.   



pabloqa

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Posted 03 June 2024 - 12:56 AM

Hi Glenn,

Thanks for your reply!

At this moment, only organic certification, however, as this is a new supplier I wanted to send samples for testing as a verification measure. So I was wondering if someone has more experience determining what specific tests are needed for drug residues specifically.

I appreciate any advice.

Best regards,

Pablo.
 

Does your supplier of the ORGANIC honey have a non-gmo and/or Organic certification???



TimG

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Posted 03 June 2024 - 12:15 PM

Good morning Pablo, I sell organic honey. We typically provide our organic cert, color, and moisture content to our customers with the load and that's it. However, we perform risk-based testing on all INCOMING honey depending on country of origin, and many of those tests you listed are included.

To address the organic/non-gmo discussion, Non-gmo in no way certifies a product as organic, however organic is non-gmo by definition. Also, the NOP has pretty strict guidelines as to what can be labeled or sold as Organic.





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