The internet has opened the door to many food operations to sell products. People often base their decision for purchasing based upon that website. Unfortunately, there is little more to go on than that. But is that enough? Recently, FDA inspected a Berkley California operation, Living Tree Community Foods, Inc. (https://www.livingtreecommunityfoods.com) and found that they were not producing foods to the required food safety standards.
Living Tree Community Foods, Inc, a Berkeley, CA processes organic seeds and tree nuts into ready to eat (RTE) organic seed and nut butters as well as repacks a variety of RTE and non RTE food products. The company had a Food Safety Plan, but was basically there for show in that it did not really address the hazards associated with the process. Company processes 25 different RTE nut & seed butters but "the hazard analysis did not identify biological, chemical, and physical hazards associated with these products and with tree nuts/seeds as significant hazards which require a preventive control at receiving, storage, slicing nuts and seeds, holding in bin, mixing (b)(4)/cooling, and/or packaging steps."
Biological hazards - the "presence of pathogenic bacteria” associated with the company's seeds and tree nut ingredients at the receiving step, but the company determined that the hazard was not significant. The company cited prerequisite programs including “Approved Supplier Program,” “Good Manufacturing Practices” and “Receiving and Storage Practices. However, “Preventive Control #1 – Approved Supplier Program which includes Continuing Letters of Guarantee and Specifications” at the Receiving Step as the control that will be applied to ensure only approved materials are received. In the company response dated April 28, 2023, the company provided a revised “Approved Supplier Program Version 3.” but these responses did not indicate what requirements the supplier must meet to demonstrate control of the pathogen hazards.
Allergen hazards - the hazard analysis in your “Food Safety Plan for Nut and Seed Butters, Muesli, Bars, and oils Version 2” did not consider the hazard of allergen cross contact as a potential food safety hazard at the slicing, or mixing steps to evaluate whether it requires a preventive control. The firm considered “allergen cross contamination” at the packaging/filling processing step; however, it was determined that that the hazard was not significant. Also did not identify and evaluate the hazard of undeclared allergens due to an incorrect label as a known or reasonably foreseeable hazard to determine whether it requires a preventive control.
Mycotoxins - in the hazard analysis for mycotoxins associated with the seeds and tree nuts as a potential food safety hazard to evaluate whether it requires a preventive control; the firm determined that the hazard was not significant based on ingredient and supplier history. Tree nuts and seeds are known to be associated with aflatoxins.
GMP issues - equipment and utensils were not designed and were not of such material and workmanship as to be adequately cleanable and were not adequately maintained to protect against contamination. The firm did not take reasonable precautions and measures to ensure that all persons working in direct contact with food wash hands thoroughly (and sanitize if necessary to protect against contamination with undesirable microorganisms) after each absence from the workstation and at any other time when hands may have become soiled or contaminated.
Labeling claims made on the labels were cited as well.
FDA Warning Letter
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/living-tree-community-foods-inc-656541-03042024
Living Tree Community Foods, Inc.
MARCS-CMS 656541 — MARCH 04, 2024
