• HACCP and the United States: food safety and bioterrorism

    Imports of coffee into the United States are all subject to inspection by the United States Food and Drug Administration (FDA) under the provisions of the Federal Food, Drug and Cosmetic Act. To pass for importation coffee must be free of unapproved pesticide residues, have had no or only limited exposure to insect infestation in the field, and be free of all chemical and other contamination including mould and live insects. Insect damage by itself, pinholes for example, exceeding 10% may also lead to rejection. The Green Coffee Association (GCA) contracts routinely contain the clause 'no pass - no sale' which puts the responsibility for passing the FDA inspection firmly on the exporter.

    The tragic events of 11 September 2001 catapulted both domestic and imported food security into top priority in the United States, with consequent strengthening of FDA surveillance of imported foods. This is visibly demonstrated by much stricter FDA and Customs inspection of coffee containers and even coffee samples, and the distribution of an FDA Food Security Preventative Measures Guidance circular to food importing operations. These measures also include a large 'track and trace' element. For more information on all this and FDA coffee regulations go to www.cfsan.fda.gov. Also, ask for the information booklet 'Health and Safety in the Importation of Green Coffee into the United States' from the National Coffee Association of the United States.

    The Public Health Security and Bioterrorism Preparedness and Response Act requires all facilities engaged in the 'manufacturing, processing, packing or holding food for consumption in the United States' to be registered with the FDA. This includes all exporters of coffee or for that matter any other primary commodity exporting to the US and some processing plants. This information needs to be updated each time there is a change. The regulations and much related information can be found on www.cfsan.fda.gov as well. The main point at issue here is that food shipments from unregistered suppliers are subject to refusal of admission into the United States. This includes coffee!

    A fact sheet is available at www.ncausa.org whereas related information (on shipping security) is also available in topic 05.04.01 of the Coffee Guide.
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