FSMA Part 2: Roasting and Brewing

FSMA Part 2: An interview with Donna Schaffner and what we all need to know about Roasting and Brewing.  

RNY is dedicated to making sure the information regarding FSMA is as available and as concise as possible for our customers. Through the next few parts of our continued blog postings we will review and go over specifics regarding the coffee and tea industry from roasting, storing, cold brew and more.

Ms. Donna Schaffner is the Associate Director: Food Safety, Quality Assurance & Training at Rutgers University – Food Innovation Center.

We are pleased to introduce you to Donna as she has 20+ years as a HACCP specialist Food Safety Consultant in USDA and FDA plants, and teaches HACCP, Preventive Controls for Human Foods (PCHF), Food Defense, Microbiology, and food safety classes in the US and abroad. She develops customized training programs for processing plants to implement HACCP or PCHF, improve audit scores, meet regulatory demands, and solve food safety and quality problems. She serves on: FDA’s Food Safety Preventive Controls Alliance, CASE Food Science & Safety curriculum development, NJ Ag Education Advisory Council, Executive Board member of the NJ Food Processors Association & chairs monthly QA Roundtable meetings for the NJFPA, and 2016 member of the Food Safety Summit Educational Advisory Board.

Ravi Kroesen, one of our 3 onsite PCQI (Preventative Controls Qualified Individual), had taken his certification class instructed by Ms. Schaffner.  Since then, RNY has engaged Ms. Schaffner and asked her a number of questions regarding FSMA and Food Safety Programs we and our customers might have to undertake. Here we have included a discussion regarding roasting and hot brewing coffee and tea.

Question: Are coffee beans included / covered in the new FSMA regulations?

Answer: Coffee beans are listed as “rarely consumed raw” and excluded from being subject the Produce Regulations, however, they are NOT excluded from the Good Manufacturing Practices regulations or requirement for processing in a sanitary environment.  Language around exclusions for coffee beans indicate that they must go through a “kill step” such as the roasting operation or process, before consumption… but a food processor who then takes the roasted coffee beans and uses them as an ingredient to make a “cold brewed coffee beverage” would be subject to all of the same Food Safety regulations as any other food processor because they are handling / processing the ingredient AFTER the “kill step” where it could become unsafe for consumption from environmental exposure.


Note: â€œTea leaves” are NOT included in the list mentioned above – there is NO specific exclusion of tea from any of the food safety regulations.

Question: Are there any effective kill steps for the coffee roaster, consumer or tea consumer considering the commodity (tea) and processed commodity (roasted coffee) may have been served after having added water that approaches the boiling point?  

Answer: There is no FDA approved kill step for coffee or tea at this time.  The FDA would require proof that the process of steeping (tea) or roasting/brewing (coffee) would eliminate potential microbiological threats.  

Note: There have been no studies or analyses that provide proof that coffee or tea with a pathogen prior to the process had been eliminated due to the processing.

Note: Given the fact there is no history of food poisoning outbreaks for hot brewed coffee and very little history for tea, regarding microbiological hazards due to a pathogen, this could be categorized as historical data defending the method of hot brewing. 

What does this mean to you – the roaster, coffee consumer and or tea consumer.

– This means that at this point in time having none or very little history of a food hazard due to a pathogen from hot brewed coffee or hot steeped tea, there is no required or mandated “kill step” regarding a specific temperature needed for roasted coffee or specific degree in hot brewing your favorite coffee or tea drink. Traditional brewing methods are deemed safe.  

Stay tuned for part 3 where we dive into even more specifics concerning the coffee and tea industry.

To submit your FSMA related questions, please email We will do our best to respond in a timely manner.

Thank you from the Royal NY Team.

This Blog is made available by Royal Coffee New York and Royal Tea New York for educational purposes only as well as to give general information and a general understanding of some food safety requirements, it is not provided for any specific food safety circumstance.  This Blog should not be used as a substitute for competent and qualified food safety guidance from a food safety professional.