This Warning Letter highlights additional issues that are important when writing and implementing the plan.
The company did not consider pathogens as a hazard in this RTE product.
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/golden-grains-bakery-688860-12202024
Golden Grains Bakery
The company did not consider pathogens as a hazard in this RTE product.
"The hazard analysis contained in your Food Safety Plan for Cold Pressed (Unbaked Products), dated October 17, 2022 (“food safety plan”), did not consider vegetative bacterial pathogens as a known or reasonably foreseeable hazard for coffee, hemp seeds, and chia seeds to determine whether they require a preventive control. You contract manufacture RTE “Java Jolt Blender Bombs” containing these ingredients, which have been associated with vegetative bacterial pathogens (such as Salmonella spp.). These ingredients do not receive a lethal treatment in your facility."
The hazard analysis contained in your Food Safety Plan for Cold Pressed (Unbaked Products), dated October 17, 2022 (“food safety plan”), did not consider vegetative bacterial pathogens as a known or reasonably foreseeable hazard for coffee, hemp seeds, and chia seeds to determine whether they require a preventive control. You contract manufacture RTE “Java Jolt Blender Bombs” containing these ingredients, which have been associated with vegetative bacterial pathogens (such as Salmonella spp.). These ingredients do not receive a lethal treatment in your facility.The metal detector was identified as a preventive control, but was not operated as though it was a preventive control. What is more interesting is that the response to FDA was not adequate. It is important when responding that one not only shows it was fixed, but provide proof the fix actually works.
"We reviewed your response, including the video you sent showing products being sent through a machine, which was presumably a metal detector. Although your response indicates that this machine was a metal detector, and you provide a metal detector drawing (dated November 19, 2015) that presumably depicts the equipment shown in the video, the video does not provide a complete view of the equipment to allow us to confirm what is being shown. Further, you did not provide any metal detection monitoring records to document the results of the metal detection activity purportedly being shown in the video."
Another issue was environmental pathogens as a hazard but did not put in proper sanitation preventive controls.
[The company] "did not implement your sanitation preventive control for the environmental pathogens hazard. Your food safety plan identifies environmental pathogens as a hazard requiring a preventive control at various processing steps, such as mixing, tumbling, coating, and packaging, where the RTE “Java Jolt Blender Bombs” are exposed to the environment. These steps occur prior to your products being sealed. The packaged food does not receive any further lethal treatment or otherwise include a control measure (such as a formulation lethal to the pathogen) that would significantly minimize the pathogen."The company did not follow their own procedures on following corrective actions for a positive Listeria species finding.
You did not follow the corrective actions outlined in your Environmental Monitoring – Listeria procedures, dated June 1, 2021, when you were notified of a presumptive positive Listeria spp. finding on August 24, 2023, for which your facility waived confirmation. According to your Environmental Monitoring – Listeria procedures in effect at the time, when a positive Listeria spp. result occurred, your facility would conduct follow-up environmental sampling that consisted of “(b)(4) swabs total; (b)(4) swabs a day taken on (b)(4) consecutive production days” and send the swabs to a third-party laboratory for analysis. However, your Microbiological Swab Test Logs from August 24-26, 2023, showed that a total of only (b)(4) swabs were taken ((b)(4) swab per day) instead of the required (b)(4) swabs total. Furthermore, instead of sending the swabs to your third-party laboratory for analysis, you tested the swabs in-house.FDA Warning Letter
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/golden-grains-bakery-688860-12202024
Golden Grains Bakery
MARCS-CMS 688860 — December 20, 2024
Recipient:
Marc L. Singer, Owner
Ronald L. Nadel, Owner
Golden Grains Bakery
547 Griffith Road
Charlotte, NC 28217-3517
United States
Recipient:
Marc L. Singer, Owner
Ronald L. Nadel, Owner
Golden Grains Bakery
547 Griffith Road
Charlotte, NC 28217-3517
United States