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Code of Practice: Processing of Bee Products

3 HACCP Application for the Processing of Dried Pollen

Amendment 0

July 2005

3.1 Scope

Table 1: Scope of the HACCP application

Components	Description/Details
Material being processed	Fresh or frozen pollen
Products	Dried pollen
Process	From receipt of pollen to dispatch of packed dried pollen. Key processing operations: • Drying • Cleaning • Freezing • Packing • Storage

3.2 Product description

Table 2: Intended use and consumer of products, and product requirements

Product	Dried pollen
Intended consumer	Humans (general public)
Intended use of product that leaves RMP	• Ready-to-eat • Ingredient for preparation of other foods and dietary supplements
Regulatory limits 1	None
Other regulatory requirements specific to bee products	Every consignment of pollen must be provided with an Apiarist and Beekeeper Statement (i.e. Harvest declaration) and comply with the requirements of HC Spec 108 2
Labelling	Labelling of retail packs as specified in the Food Standards Code including an advisory statement as required by Standard 1.2.3. Labelling of transportation outers as specified in HC Spec 32.

1. Regulatory limits are limits that are essential to be met for food safety and are established by the regulator under the Animal Products Act 1999.

2. The Apiarist and Beekeeper Statement (i.e. Harvest declaration) confirms the controls applied by the beekeeper that are intended to minimise the risks to human health from drugs (e.g. antibiotic), agricultural chemicals (e.g. pesticides), and plant toxins, including phytotoxins of the native plant tutu (Coriaria spp).

3.3 Process description

The process flow diagrams show the key steps based on a generic process. Process steps and their sequence may differ for each premises. Operators must ensure that their process is accurately reflected in their RMP.

Table 3: Process flow diagram for the processing of dried pollen

Inputs 1	Process steps	Outputs 2
Fresh or frozen pollen →	1. Receiving
	↓
	2. Holding in freezer
	↓
	3. Drying
	↓
	4. Cleaning and sorting	→ Foreign matter to waste
	↓
Packaging →	5. Bulk packing
	↓
	6. Storage in freezer
	↓
Packaging and labels →	7. Retail packing and labelling
	↓
	8. Dispatch	→ Packed dried pollen

1. An input is any material, additive, processing aid, ingredient, or packaging that is added or used for the production or processing of a food product.

2. An output is any material or product resulting from any operation under an RMP.

3.4 Hazard analysis and CCP determination

3.4.1 Identification of hazards from inputs

Hazards associated with each input are identified, considering any supplier agreements and requirements given in the COP.

Table 4a: Hazard identification

Inputs	Description/specification	Biological hazard (B)	Chemical hazard (C)	Physical hazard (P)
Fresh or frozen pollen	Accompanied by an Apiarist and Beekeeper Statement (i.e. Harvest declaration) and complies with HC Spec 108.	Bacterial pathogens from rodent droppings, insect fragments and wastes, dusts and other contaminants1	Chemical residues, e.g. pesticides 2 Allergen 3	Wood, metal pieces (e.g. staples, wire)
Plastic packaging	Suitable for use as food contact material as specified in Section 8 of Part 2 of the COP.	None	None	Plastic pieces
Glass jars	Suitable for use as food contact material as specified in Section 8 of Part 2 of the COP.	None	None	Glass fragments

1. At present, there is insufficient information on the types and levels of pathogen contamination on bee pollen. Further investigation on this matter is proposed.

2. The potential for chemical residue contamination in bee pollen is minimised by controls at the apiary, and confirmed through the Apiarist and Beekeeper Statement (i.e, Harvest Declaration) as required by the Human Consumption specification 108. This statement confirms the controls applied by the beekeeper that are intended to minimise the risks to human health from drugs (e.g. antibiotic), agricultural chemicals (e.g. pesticides), and plant toxins.

3. The ingestion of bee pollen has been identified as a possible cause of anaphylaxis, gastro-intestinal symptoms, asthma, and angioedema/urticaria. The Report of the New Zealand Bee Product Warning Scientific Review Working Group (1999) concluded that the estimated risk to the population from ingestion of bee pollen is extremely low. The Working Group also concluded that risk management should be limited to ingredient labelling of all products containing bee pollen.

3.4.2 Process step hazard analysis and CCP determination

Table 4b: Hazard analysis and CCP determination for the processing of dried pollen

Process step	Inputs	Hazard reasonably likely to occur on or in the product at this step	Justification	Q1. Is there a control measure(s) for the hazard at this step? If yes, identify the control measure and then answer Q2. If no, consider hazard at next step.	Q2. Is the control measure at this step essential to food safety as defined by a regulatory limit? If yes, this step is a CCP. If no, this step is not a CCP.	CCP no.
1. Receiving	Fresh or frozen pollen	B – Bacterial pathogens	Bacterial pathogens may be present in fresh pollen from contaminants such as rodent droppings, insect parts and wastes, dust	Yes – Supplier agreements and inspection for contaminants at receipt will minimise contamination	No
		C – Chemical residues	Residues can occur in pollen1	Yes – Supplier statements confirming beekeeper controls	No
		C - Allergens	Pollen is known to cause allergic reactions in certain people	No 2
2. Holding in freezer	Pollen	B – Bacterial pathogens	Carried over from previous step	Yes – GMP: proper freezing will prevent micro growth 3	No
3. Drying	Pollen	B – Bacterial pathogens	Carried over from previous step	Yes – Proper drying may reduce micro levels and prevent micro growth 3	No
4. Cleaning and sorting	Dried pollen	B – Bacterial pathogens	Carried over from previous step	Yes – GMP: effective cleaning and removal of dust, insect and other physical contaminants can reduce micro levels 3	No
5. Bulk packing	Dried pollen	None
	Packaging	None
6. Storage in freezer	Dried pollen	None
7. Retail packing and labelling	Dried pollen	C - Allergen	Carried over from step 1	No. Labelling will not control the hazard but it will minimise the risk to the consumer 2
	Packaging	None
8. Storage	Dried pollen	C – Allergen	Carried over from previous step	No
9. Dispatch	Dried pollen	C- Allergen	Carried over from previous step 2	No

1. The control of chemical residues involves effective beekeeping practices which is confirmed through the Apiarist and Beekeeper Statement (i.e. Harvest Declaration) as required by the Human Consumption specification 108. There is insufficient data, at present, to confirm the levels of chemical residues in New Zealand pollen. The level of any chemical residue is not going to increase during pollen processing, thus, they have not been considered further in succeeding steps.

2. The Report of the New Zealand Bee Product Warning Scientific Review Working Group (1999) concluded that management of risks from allergens in bee pollen should be limited to ingredient labelling of all products containing bee pollen. The Food Standards Code 1.2.3 requires that the label on a package of bee pollen must include an advisory statement to the effect that the product contains bee pollen which can cause severe allergic reactions.

3. There is insufficient information, at present, on the impact of certain process steps (e.g. freezing, drying, cleaning) on the microbiological load in bee pollen. Limited industry data suggests that proper collection of pollen, application of GMP during processing and the thorough removal of physical contaminants minimises the microbiological load in bee pollen. The hazard analysis shown in this table is based on limited industry information, and scientific information on the general impact of these process steps on microorganisms in food. Further investigation is necessary to confirm the hazard analysis.

3.4.3 Outcome of CCP determination

No CCP was identified for the drying of bee pollen. The control of hazards at key steps is expected to be adequately addressed by GMP (i.e. complying with the procedures given in Part 2 of this COP).

Since no CCP has been identified, the other HACCP principles that relate to a CCP (i.e. identification of critical limits, CCP monitoring, CCP corrective action) have not been applied to the generic process.