The California Department of Public Health (CDPH) has recently been chasing down the cold-press juice industry, citing companies for non-compliance with FDA’s Juice Hazard Analysis and Critical Control Point (HACCP) regulations. According to CDPH, cold-press juice processors are failing to incorporate a processing step involving a minimum “5-log reduction” of microorganisms into processing standards – an FDA Juice HACCP requirement. If CDPH continues its pursuit it will kill the cold-press juice industry in CA for no good reason.
I know what you’re thinking. “Wait! It’s legal to buy marijuana in CA but not Cold-Press Juice?”
Decades ago, FDA concluded that certain types of food were more vulnerable to contamination during processing than others, and so created the HACCP regulations to ensure that those foods were processed in a manner to mitigate the risk of those food hazards. One of the Juice HACCP requirements is the use of a processing step that results in a minimum 5-log reduction for microbiological contamination. It usually involves heating the juice and then challenging the heating step to verify that the number of microbes (in an inoculated sample) was reduced to a number 100,000 times smaller than existed prior to processing.
Cold-pressing is a method of juice preparation where ground fruits and vegetables are pressed through a permeable pouch so that the only thing left in the pouch is the nearly-dry pulp. Fans of cold-press juice support the method for its health benefits, saying that heating juice kills the desirable enzymes and nutrients. There are other methods for reducing potential micro-organism contamination, but none except heating (pasteurization) achieve the minimum 5-log reduction required by FDA’s Juice HACCP. The heating step, however, removes the characterizing attraction of cold-press juice altogether — and with it the industry that supplies it.
Of course, FDA objects to anything that is less processed — less needful of their expert oversight. Raw milk and raw oysters should be contraband and so, it seems, should cold-pressed juice. Obviously, micro-filtration, UV, or pascalization, coupled with cold-chain controls, is capable of reducing product bioburden and ensuring that microorganisms do not proliferate during the product’s lifecycle. There are no adverse events to speak of from the consumption of cold-press juices, and the product labels clearly identify that the products have not been pasteurized. CDPH apparently has not thought this through. Instead, it is latching onto FDA’s 5-log reduction requirement and applying the state’s broad enforcement authority to stop-sale or seize cold-press juice product without first evaluating the policy or food safety considerations.
Is fortified pasteurized orange juice safer or as healthy as natural, fresh (i.e. local) cold-press juice? Isn’t CA in the orange-growing business? Whatever did we do before we had FDA to tell us we had to heat our juices? And why a 5-log reduction? Why not 6 or 4? And if a Juice processor complies with Juice HACCP will it guarantee the juice will not be contaminated or merely reduce the risk of food safety hazards?
If CDPH continues to press this issue the industry will find itself broke and out in the cold — and we will have to cold-press our own juices, off the grid. Just don’t let FDA find out about it! They will accuse you of shucking raw oysters and drinking beer too.
