FDA FSMA Coffee Roasting Regulations

This is our second post dedicated to the subject of the FDA Food Safety Modernization Act (FSMA) and how it relates to coffee and tea.  Our goal is to help our customers better understand their responsibility in relation to this Act.  For part two, we sat down for an interview with Donna Schaffner.  Here, Donna shares all we need to know about FDA coffee roasting regulations.

Our goal at Royal New York is to make sure the information regarding FSMA compliance is available and concise for our customers. Through the next few parts of our blog posts, we will go over specifics relating to the coffee and tea industry.

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 over 20 years as a HACCP specialist Food Safety Consultant in USDA and FDA plants.  Donna teaches HACCP, Preventive Controls for Human Foods (PCHF), Food Defense, Microbiology, and food safety classes in the US and abroad.  Additionally, she develops customized training programs for processing plants to implement HACCP or PCHF.  Through these programs, they 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.

Our team sat down with Ms. Schaffner and asked her several questions regarding FSMA and Food Safety Programs.  Here we have included a discussion regarding roasting and hot brewing coffee and tea.

Royal New York FSMA fundamentals chart

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

Coffee beans do not have to meet the Produce Regulations since they are rarely consumed raw.  However, they are required to meet Good Manufacturing Practices regulations or requirement for processing in a sanitary environment.

Language around exclusions for coffee beans indicate they must go through a kill step before consumption.  The coffee roasting process is an example of a kill step.  However, a food processor who then takes the roasted coffee beans for cold brew is an exception.  They would be subject to all of the same Food Safety regulations as any other food processor.  This is because they are handling / processing the ingredient AFTER the kill step.  In this way, cold brew could become unsafe for consumption from environmental exposure.


Note: They do not include tea leaves in the list mentioned above.  There is NO specific exclusion of tea from any of the food safety regulations.

Since you will probably serve the commodity after the water approaches the boiling point, are there any effective kill steps?

There is no FDA approved kill step for coffee or tea.  The FDA does require proof that steeping (tea) or roasting/brewing (coffee) will eliminate any microbiological threat.

Note: There is no history of food poisoning outbreaks from hot brewed coffee. Additionally, there is very little history for tea regarding microbiological hazards because of a pathogen. Therefore, one could categorize this as historical data defending the method of hot brewing.

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

– There currently is little to no history of a food hazard due to a pathogen from hot brewed coffee or hot steeped tea. Because of this, there is no required kill step for a specific temperature for roasting or brewing coffee or tea. They deem all traditional brewing methods safe.

Specialty coffee sample roasting at Royal New York

Specialty tea brewing at Royal New York

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

Do you have FSMA related questions?  Please contact us or email!

Thank you from the Royal NY Team.

Royal New York makes this blog available for educational purposes only.  Our goal is to give general information and an overall understanding of some food safety requirements.  We do not provide it for any specific food safety circumstance.  Do not use this blog as a substitute for qualified food safety guidance from a food safety professional.