Food Safety Practices Guidance for Moulded Chocolate Manufacturers
Preface

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According to the National Confectioners Association (NCA), chocolate is the top selling confectionery – over gum, mints, gummies, licorice and other sweets. Chocolate sales in North America topped $16.3 billion in 2007, representing over 3.5 billion pounds of chocolate (NCA 2011). While chocolate continues to grow in popularity, the emergence of a number of food recalls associated with Salmonella spp. contamination and undeclared allergens, as well as a recent outbreak of food-related illness linked to chocolate products, suggest that manufacturers may need to consider new approaches to improve the safety of chocolate.

The potential for raw cocoa beans to be contaminated with Salmonella spp. is well established. Canada's Food and Drug Regulations specifically address this hazard with Section B.04.012 which prohibits the sale of cocoa or chocolate products containing Salmonella. Unless roasting of the cocoa bean is adequate and handling of roasted beans is well controlled, the intermediate chocolate products such as cocoa powder, cocoa butter or cocoa liquor may be contaminated with Salmonella spp. (ICMSF 1986). The low water activity of these intermediate products is known to increase Salmonella's resistance to heat, such that small numbers of Salmonella spp. have been shown to survive typical temperatures reached during the milling, refining, or conching steps of chocolate processing (Lund et al. 2000). Salmonella spp. can also be introduced to chocolate products by other contaminated ingredients, by contaminated processing equipment or by inappropriate employee handling practices.

For individuals with food allergies, consuming a pre-packaged food containing an undeclared allergen can be life-threatening. Priority food allergens of concern in Canada include: peanuts, tree nuts, milk, soy, wheat, sulphites, sesame seeds, eggs and seafood (fish, crustaceans and shellfish). Undeclared allergens can be present in a pre-packaged food as a result of cross-contamination or carry-over, inadequate allergen control on incoming ingredients, inappropriate use of rework, the application of an incorrect label or an incorrect list of ingredients on a label.

Risk can be significantly reduced through strict adherence to Good Manufacturing Practices, especially where the principles of Hazard Analysis Critical Control Points (HACCP) are applied to the process.

In an effort to help reduce the risk posed by Salmonella spp. and undeclared food allergens in moulded chocolate and to assist manufacturers that wish to adopt a Hazard Analysis Critical Control Point (HACCP) approach, CFIA has developed the Food Safety Practices Guidance for Moulded Chocolate Manufacturers document. The guide uses the General Principles of Food Hygiene and Consumer Packaging and Labelling (GPFHCL) as its core and has incorporated additional reference material to create a suggested prerequisite program. Developed by the CFIA with input from a number of interested parties, including the Canadian chocolate industry, Health Canada and provincial government representatives, this document provides guidance on potential hazards and controls related to a HACCP approach. As well, this guidance document is designed to address other factors that affect product integrity, including composition, compliance with standards, and labelling requirements. This guidance document is being offered to manufacturers as a food safety resource.

HACCP is a systematic approach that assesses each step in a food manufacturing process for potential hazards. HACCP is recognized by regulators, industry and academia as a reliable food safety approach available to the food industry. Prior to the application of a HACCP system, an establishment should be operating in accordance with Good Manufacturing Practices (GMPs), applicable food safety legislation and should have the guidance of a person trained in HACCP. The GMPs (prerequisite programs) serve as the building blocks upon which a HACCP plan is built.

A HACCP system is developed following a careful review and analysis of the unique processing facility in which it is to be implemented. Chapter 1 of this guidance document primarily provides guidance related to hazard analysis and control of the manufacturing process, while chapters 2 to 8 provide guidance related to a generic prerequisite program. The intent of this guidance document is that processors wishing to develop their own HACCP program can modify or adapt this generic guide to suit their particular facility and operation.

It is hoped that this document will complement existing references and the initiatives of other agencies, to make it easier for chocolate manufacturers to adopt a HACCP approach and ultimately produce the safest possible product.

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