Raw / Unpastuerized : Retail Juice Processing step by step

Juice Makers Association
1

Hello Everyone,

I spoke with the local health department about Raw Juice / Unpastuerized Juice. Here are some notes…

Must be (State of CT)

1.Store Front / Brick n Motor
2.Direct to Consumer
3.No Bottling or Ready to go Bottling
4.Low PH fruit or vege
5.Temperature control for safety
6.Carrot not allowed ( Case Botulism in the past)
7. Must have a HACCAP plan

When i mentioned that the overall population are aiming to make better food and beverage choices,how is the local health department going to support that or in fact when was the last time all that information been “updated”.

Health Department:
She noted that there should be some changed pertaining to Unpastuerized Juices but we have not got any followup or duration of the process.

Reference:
UCONN Food Safety Plan for Retail Juice Processors Step By Step, 80 pages.

My Question:

Can a HACCP plan “override and waive” these requirement when it comes to Unpastuerized or Raw or Unpastuerized Juices. I strongly believe there is a way .

2

Hi Chrissy,
I will attempt to help you point by point as best as I can. I operate in NV, so the information may be different. Also, if you haven’t already, you should strongly consider joining the Juice Makers Association that recently formed in November. They posses a HACCP Plan template which can greatly help you get started.

  1. Health Departments require a kitchen or commissary for a juice business to operate in. This has to be inspected and rated the same as a restaurant. Since you are most likely not HPP your juices, it must be direct to the customer. Hence a storefront.
  2. All unpasteurized juices must be direct to customer in all of the US.
  3. No bottling is odd. This may be just a CT thing, but my feeling is that until you have a HACCP Plan in place you cannot bottle as it is an increased risk if pathogen contamination. Bottling or Reduced Oxygen Packaging (ROP) can create an environment which bacteria grow very quickly. A HACCP plan shows the health department that you are taking the needed step to minimize risk.
  4. The low pH again is to prevent bacteria growth. Again, just like #3 the health department wants to make sure you are keeping risk to a minimum. But for you to make juice at 3.5pH or lower, or 11.5pH or higher (that is the needed levels to kill bacterial growth) is nearly impossible. You will have to push back on your health department on this issue.
  5. Temperature control is paramount. This is for everyone that makes juice. Once you start producing juice you have 4 hours to get the temperature to 41 degree F or lower.
  6. The no carrots is again, something you will have to push back with the health department. Carrots are a federal GRAS ingredients (Generally Recognized As Safe). Spinach is often recalled due to e.coili, but there has not been a ban on it. It can still be used in juicing. Sounds like the health department had a problem with someone using bad/ rotten produce in the past.
  7. This is a must! You must have a HACCP plan. You can consult with Ari Sexner to assist you, or if you join the Juice Makers Association, you can get a template and SOPs to aid you.
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3

Thanks You so much for this information.

Where do I go to enroll in the Juice Association

4

https://juiceassociation.org. You will have to sign up for emails in the contact form, and then request to join as a member of the JMA.

5

I just added this topic:

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6

I am new to juicing and plan on taking HACCP training myself for certification. I was also a restaurant operations director and have a few other food safety licenses (may need to revisit).

Do you think I’d be able to write my companies HACCP plan myself once training is complete or should I look into hiring someone?

I’m interested in joining the Juicing association as well. I do not have a brick and mortar and intend on making my juice out of a rented commercial kitchen. I have a TON of questions, this forum is a great space to learn! I’m started off small scale so I am trying to understand which rules apply and don’t apply to smaller businesses. As per now I am a one woman show, the demand is high, but I am attempting to get all of the legalities in order prior to increasing volume.

Any help or aid on HACCP thoughts are appreciated!

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Hello, I posted some more details on the other comment in the different channel. We can set up a quick call if you would like to go over something before you talk to the health department. Not always the case but the way the regulation should be as follows, if you do any form of transportation of raw juice, in a bottle that is capped. It is considered a special process (Reduced oxygen packaging) and will require a HACCP for this special process. It is considered transportation if you are making transporting it outside of the inspection area.

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