Here is a question I posed to the FDA TAN (Technical Assistance Network) to further clarify (or confuse) regarding commissaries and FDA Preventive Controls requirements.
WAFDO Digital Active Managerial Control Presentation Aug 2019
Rejuvelac is essentially a natural (yeast and lactic) fermentation of sprouted grains. One person quoted something to the effect of at its peak it is a pleasant tonic, but fermented too long or fermented wrong, it is simply putrid. If the grains were rye, it could be called Kvass (Russian or Slavic origin). There are three general steps:
The soaking and sprouting steps are essentially the same as “sprouting” in the food code or in FDA guidance. Sprouting grains should be carried out in acidified water OR at refrigeration temperatures. Ambient temperatures are not needed for seeds or grains to sprout.
After sprouting, the sprouts and husks are rinsed in potable water. The acidified water is not needed for the rinse. Fermentation is the next step. Water is added to the sprouted seeds. An ACTIVE culture should be added. A wild fermentation is not recommended. One concern with this process is the possible presence of bacterial pathogens. Salmonella has been implicated in foodborne illnesses in sprouts and Bacillus cereus in grains and rice. Note that Kvass and sourdough bread processes have a heating step and baking step respectively. Rejuvelac does not. In fact it is advertised as ‘raw”. The control, therefore, is to have a culture that is active and ferments rapidly. An active culture provides competitive inhibition, reduces available nutrients and lactic acid bacteria fermentation reduces the pH. The concern then is that if one relies on the natural wild biota to grow from a few cells to many, during this time, pathogens can also grow from a few cells to many.
A natural sprout biota (wild) culture will likely be a mixture of yeasts and lactic acid bacteria (think sourdough bread). The natural culture is allowed to ferment the sprouted grain water producing a yeasty (bready) smell along with a lactic acid sourness. A purchased culture is more likely to be a lactic acid bacteria that will produce a yogurt like smell that has less of a bready smell.
|Soaking||All pathogens||Refrigeration ≤ 41F|
|Sprouting||All pathogens||Refrigeration ≤ 41F or acidify to pH ≤ 4.2|
|Fermenting||All pathogens||Ferment with an active culture dropping the pH to ≤ 4.2 as rapidly as possible|
|Aging||At pH ≤ 4.2 no pathogens can grow*||Refrigeration ≤ 41F for quality (not safety)|
Its been a long haul to get the course completely reviewed and determined to be compliant (approved) by the FDA.
The following is a file containing two USDA FSIS authored guidance documents on cured, fermented, and dried meats including the USDA FSIS model HACCP plan. It is recommended that retail operators wanting to produce dry and semi-dry sausage and dried whole muscle meats use this guidance to educate themselves before they consider writing a HACCP plan. Secondly, operators should become familiar with the formatting and required elements of a food code HACCP Plan as specified in the latest edition of the food code section 8-201.14.
This question comes up often. ROP requires HACCP. No ROP, no HACCP.
First, a common item exclusion for a different reason. All acid foods pH ≤ 4.2 are non-TCS. As a non-TCS food, no HACCP. So, cold bagging dressings, acidic sauces, etc does not require HACCP because its non-TCS.
What about cold bagging TCS foods, like proteins? The answer from FDA is no vacuum or removal of air, not ROP, no HACCP. Read their interpretation carefully.