Happy New Year to everyone! Here's to a healthy and prosperous 2017 filled with new accounts, fair Brazilian weather -- and fewer regulations! In my last article, I began to speculate about the possibility of less regulations in general, given our new POTUS, and how that may or may not affect us in a "close to home" fashion. Many regulations are fine and justified, but all too often, unintended consequences resulting from well intentioned policies can slow the wheels of progress so horribly as to bring them virtually to a stop.
Coffee as a food item falls under the FDA umbrella as a governing body. It's a large body that also oversees cigarettes and bedpans. (Don't ask me, I just googled it). Although coffee is lumped in with the world of foodstuffs and other presumably related items, it is not quite the danger cigarettes, or peanuts (think allergen), represent.
In its freshly brewed form it can certainly pose a threat, as was the case in the infamous McDonald's coffee scalding incident, but serving temperatures are not themselves regulated. Subsequent cases usually are defended by showing what is considered to be normal holding temperatures. (About 170°F to 185°F. has been recognized as the norm for glass bowl, carafes, airpots and thermal servers. I do not know of any single-cup cases.)
Coffee as a product is quite benign and there has never been a case of "food poisoning" (botulism, etc.) involving coffee in its solid form. It really doesn't "go bad," as it were. It certainly can get very stale, but unless it is exposed to water, it doesn't pose any threats itself. It is even known to have some antibacterial properties.
It may not pose any threat as a food item, but increasingly, large foodservice and retail clients are looking for certifications from governing bodies related to the manufacturing practices and provenance of any coffees they purchase and distribute.
HACCP, which stands for Hazard Analysis Critical Control Points, is the certificate most vaunted and requested. My company, Heritage Coffee, gained this certification to maintain its good standing where this is now required.
It is very expensive to qualify, and once you do, it is an ongoing expense, as it requires a lot of paperwork and oversight to manage, just to keep up with the requirements necessary to remain current.
It started off innocently enough. It was developed in the late 1950s by a team of food scientists and engineers from the Pillsbury Co., the Natick Research Laboratories and NASA. The team developed a system designed to build quality into a product to ensure food safety for the manned space program.
After an outbreak of E. Coli in Scotland in 1996, a report recommended that all food companies adopt HACCP standards, and the procedure has slowly evolved and crept its way to include coffee. Though no one has been hurt by coffee grounds themselves, and there is little we could do at the plant level to inflict harm through our beans and grounds, we are still required to act as if we are making soup or egg salad. OK, maybe I stretched there, but now that we are certified, I am not allowed to carry a cup of coffee around my own plant. That's right: I cannot carry the finished version of the product I produce. It is an odd and altogether ridiculous thought that I cannot do what has been done for generations but, believe me, my employees love to remind me of the fact every time I absentmindedly start to make my way back there, cup in hand.
I have broached all of the above facts with clients who require we be HACCP certified, all but begging them to give us some sort of an exemption, of the same kind we have from other regulations such as labeling laws. Unfortunately, it is seen as being too difficult at the end user level to worry about differentiating between what does or doesn't need certification, and so it is easier to require blanket compliance.
We have it and we are capable of continuing to maintain it, but as this becomes further embraced and required, what happens to small businesses that can't?
Notwithstanding all the anti-big business rhetoric, lawyers and insurers are, regardless of intent, potentially going to strangle not the big businesses, but the small businesspeople, using red tape as the garrote. HACCP represents better safety in worst-case scenarios, but at how high a cost? If my company requires two full-time employees just to keep up with something like HACCP, what chance does a mom and pop have, as smaller and smaller buyers begin to demand this at the behest of their own lawyers and insurers? I wouldn't be surprised if banks add this requirement of their clients as part of their general credit rating, alongside debt to equity ratios.
Though it may seem to many that big business harps on regulation and the need for it to be kept in check to some degree, it is actually the small business that can be far more gravely harmed by certain regulations being adopted as product- and industry-wide standards.
As always, may your cup run full, and the brew, exquisite.
KEVIN DAW is president of Heritage Coffee Co. (London, ON, Canada), a private-label roaster serving the breaktime management industries. A 30-year veteran of OCS, water delivery and vending operations, he has concentrated on coffee roasting for the past two decades.