New food product? Be prepared for inspection
Understanding the legal requirements for licensing an acidified or acid new food product along with having a business plan will help speed the process.
On many occasions MSU Product Center Counselors are contacted by individuals who are referred by the Michigan Department of Agriculture and Rural Development (MDARD) Food Licensing Division. The referrals are generated by inspectors finding a product during routine inspection of a retail store or farmers market that is not licensed for sale. One common red flag is improper labeling. While no fines are levied, the product can be seized. This results in a financial loss for the producer.
If the product is not refrigerated, baked or frozen, determining the products pH (acidity level) is required. Shelf stable products require a Process Authority Review (PAR). MSU Product Center Counselors help to coordinate this legally required activity via MSU campus faculty.
Foods that have a high pH, but can be acidified by adding additional ingredients, like vinegar or lemon juice, can receive a letter following a PAR that will allow them to produce the product. This will also necessitate the completion of a course offered by MSU, Better Process Control School (BPCS).
The U.S. Food and Drug Administration has selected Michigan State University as one of the authorized schools to present the Better Process Control School. Students who successfully complete this course will meet FDA certification requirements.
Upcoming BPCS trainings:
- Oct. 17-20, 2017 – Michigan State University, Surplus Store and Recycling Center, 468 Green Way, East Lansing, MI 48824
Registration link: https://events.anr.msu.edu/BPCSOct2017/
- March 6-9, 2018 - Michigan State University, Erickson Hall Room 228, 620 Farm Lane, East Lansing, MI 48824
Registration link: https://events.anr.msu.edu/BPCSMarch2018/
Students are tested on each section over the two-day course. A certificate will be issued upon completion.
Once the entrepreneur has completed the course and has a process authority, they can apply for a MDARD food production license. The inspector will visit the production facility (also necessary to be licensed) and visually watch the production to insure that all steps to avoid contamination are followed and that the recipe is followed.
Additional paperwork should include, Standard Operating Procedures (SOP), Standard Sanitary Operating Procedures (SSOP) and in certain instances, Hazard Analysis Critical Control Points (HACCP) plan. Recall procedures are a part of the SOP.
Michigan State University Extension Educators working with the MSU Product Center guide potential food product producers in development of necessary paperwork for licensing.