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Food Safety Food In Canada Regulation Beverages CFIA cold-brew health and safety Kombucha

Whether the beverage is new or old to the market, there are still challenges when it comes to food safety

Sales of kombucha and cold brews are soaring as consumers seek out healthy beverage alternatives. But scaling up these traditional drinks that have been made in small batches for hundreds, if not thousands of years, is not without challenges.

Food in Canada spoke to industry experts and manufacturers about the steps they are taking to ensure regulatory compliance and food safety while maintaining traditional brewing methods for kombucha and cold brew.

Although cold brew can contain coffee or tea, it isn’t brewed in the same manner as its traditional “hot” counterparts. Kombucha is a fermented tea made from green or black tea, also known as symbiotic culture of acetic acid bacteria.

“All of the new products’ safety is kind of questionable sometimes because the assessment for safety hasn’t been conducted properly,” said Angela Tellez-Lance, food safety and risk analysis expert. “In some cases, like the cold brew, they start selling and the next thing you know they’re recalling. There are many cases of products that the companies launch, and six months later they have a recall. It’s because the product was not properly developed.”


Kombucha is a fermented tea made from green or black tea, a symbiotic culture of acetic acid bacteria and yeasts. The health benefits for kombucha are like many other fermented products. Unpasteurized products usually contain probiotics, which are good for the gut.

For kombucha, a sweet tea is made as a base then moved into a metal or plastic vat for fermentation. A blend of yeast and bacteria (SCOBY) are added to the mix, then sits to ferment at slightly warmer temperatures hovering closer to 80 Fahrenheit from anywhere between seven to 30 days. The longer the fermentation, the more sour the product.

Unlike other beverages, such as juice, kombucha never reaches a boiling point or goes through a pasteurization process, meaning there is no kill point for pathogens.

The biggest challenge when producing fermented products are fruit flies, said Drew Butterworth, founder of Good Vibes Juice Co.

“Typically producers might use techniques like keeping a bit of wind or a fan running in their fermenting room.”

He also said that use of cloths over the juice will help keep flies away.

Kombucha isn’t like any other drink or food product that has a step by step process or guidelines to follow, it is completely up to the processor to determine when the product is complete and ready for consumption.

“One of the best ways [to determine this] is taste, making sure the product fermented to the way you like,” said Butterworth. “A little more on the scientific side is measuring the pH.”

Measuring the pH level indicates that the product is fermented. “From a health and safety perspective, you need a pH below 4.2,” said Butterworth.

If the pH levels exceed 4.2, that means the product has not fermented long enough and becomes vulnerable to bacteria growth.

“Tea is pretty easy to inspect, if it’s dried and has all of the aromas, there’s no real sign of any concern. We’ve had a good relationship with our suppliers, we have never had any reason to question anything. Obviously there is a certain level of trust there.”

Kombucha’s primary ingredient is tea, which isn’t a new product to the beverage industry. Consumers have always considered it to be safe. But recent recalls have raised concerns about consumer practices when making tea.

In 2011, 2013, and in 2019 there were recalls for tea due to the risk of salmonella. The recalls are for loose and bagged tea, never in pods for single-serve coffee systems, said Tellez-Lance.

“The machine is designed in such a way that the tea stays heated for enough time so the salmonella won’t survive,” said Tellez-Lance.

When processing tea, the process depends on the type of tea — almost all types of tea leaves are picked and left to dry out. The kill point for any harmful bacteria is at the consumer level, not during production.

“With any agriculture product, you’re going to run the risk of E. coli or salmonella,” said David O’Connor from Genuine Tea.

Consumers risk E. coli or salmonella poisoning when they don’t let their tea steep in the hot water for at least one minute, or they don’t heat the water to a boiling point.

“The salmonella won’t grow, but it will survive. Then it is not a matter of just growing, of course, it doesn’t grow once you draw the water, but some cells will survive. The infectious cells of salmonella are low, meaning you just need a few cells to get sick.”

In Japan and China, iced tea can be pasteurized with acid then sometimes baking soda is added to neutralize the acid, said O’Connor.

“That will be the initial kill step. Then they’ll need to put acid in some form or another in order to ensure that no bacteria can grow after the first kill step.”

Packages of tea have instructions on the label, but not all consumers read the instructions on the label.

“Manufacturers today have to design products and communicate the risk in such a way that catches the attention of the consumer and is clear,” said Tellez-Lance. “The message is loud enough and very visible to make sure the consumers read and follow the instructions properly.”

Consumers have discovered different methods for making their tea, including cold brewing and sun brewing their tea. Cold brewed tea involves tea steeping in cold water from four to 48 hours, while sun brewed is tea soaked in water for at least three hours outside in the sun. Hot water is not involved in both methods.

“There’s a kill step that consumers do, which is boil the tea leaves. A lot of groups in North America will make sun tea, for example, where they put black tea leaves in room temperature water and leave it out all day. If you take that bacteria it can propagate very easily because there’s no-kill step,” said O’Connor. “If you recommend people doing cold brew… but do let them know that there are inherent risks with that. They should do it at the very least in a refrigerated environment.”

Cold brew coffee has a similar process to cold-brewed tea, where coffee brews in water for a long period of time. The primary difference between tea and coffee is that coffee beans hit a point of heat during roasting, while tea leaves do not. Fresh coffee beans are roasted to between 440 to 450 degrees Celsius for 10 to 15 minutes, which is the initial kill step in cold brew coffee.

The provincial government in British Columbia has recommended cold brew companies still brew their coffee to destroy bacterial spores, said Tellez-Lance.

At Station Cold Brew in Toronto, they soak coffee grounds anywhere from 16 to 24 hours. Their brew is a concentrated coffee that acts as their base for the drink.

“Working with concentrated and what the concentrate does, it’s got quite a higher pH than your typical, just iced coffee,” said Mike Roy, vice-president of operations at Station Cold Brew. “We’re producing a product that’s already around that kind of pH of 4, which is considered acidic enough to not have any growth as well.”

When it comes to spoilage through microorganisms, pH level is an indicator for food safety. Moulds prefer to grow in slightly acidic conditions while yeast are able to cultivate in a more acidic environment. Most bacteria is capable of forming in pH that ranges from 4.6 to 7.0.

At Station Cold Brew, they filter their concentrate through the pre-treatments that is needed, they water the product down with sterile water. The water has its own filtration system, making sure the product is sterile and doesn’t come into contact with contaminated water.

“That’s where you would find the biggest problems in this industry would be,” said Roy. “We send our water out for testing frequently to make sure that there’s nothing weird coming back or to make sure that our filtration is doing what it’s supposed to be doing.”

“Not only will it be really harsh on our filtration system, but it’s going to create a flavour profile that’s not great.”

Although cold brew coffee has cold in the title, there are methods to create a shelf-stable product. At Pilot Coffee Roasters in Toronto, they created a nitro cold brew latte with milk that uses a thermal process to ensure safety without refrigeration.

The product starts with a regular cold brew process, but milk and sweetener are added after.

“Once you have that canned product with fresh, cold ingredients inside, the difference becomes putting it through a thermal process so that you address any food safety concerns,” said Brett Johnston, head of cold brew at Pilot Coffee Roasters. “Then you have a product that can be stored at room temperature, rather than require refrigeration, which is obviously quite involved in terms of making sure you do it correctly.”

Liquid nitrogen and coffee isn’t a typical mix for your morning cup of Joe. The nitrogen added into cold brew does aid in the preservation process.

“Liquid nitrogen is so cold, it will quickly evaporate. But the idea is that you put the lid on the can so that when it evaporates, it’s in a closed environment. It’s already displaced all the oxygen, which is a bit of a packaging aid,” said Johnston. “Then when you seal it and put the lid on top and its operating, it gives the can pressure as well, so you get a good feel to the can. Then because we kind of overdose the pressure it texturizes in the can like a keg might, you get a product that has a creamy texture.”

Since cold brew coffee is a relatively new product, there isn’t any set equipment or specific standards for manufacturers. Both Pilot Coffee Roasters and Station Cold Brew manufacture their products with equipment similar to breweries that produce beer.

“It looks like we’re a beer brewery.”

Freshly brewed products, such as ice tea and cold brew, are now required to register a profile with the Canadian Food Inspection Agency (CFIA) under the new Safe Food for Canadians Regulations. Roy said the CFIA is still trying to grasp the concept of the cold brew process.

“Right now it’s like the Wild West, no one really knows what the right or wrong way to do anything is,” said Roy.

Station Cold Brew has prepared for the changing CFIA regulations by setting up their micro stats and ensure that their manufacturing process aligns with the new regulations ahead of time.

The Safe Food for Canadians Regulations are changing for the food and beverage industry. By July 15, 2020, food and beverage manufacturers will have to comply with the licences and have prevention control plans in place.

In January of this year, the Safe Food for Canadians Act and the Safe Food for Canadians Regulations came into effect. The new regulations consolidated the federal regulation in the commodity sectors, which include fruits, vegetables, and some juices.

“We have no idea who was making food in Canada and they will still not. There will be smaller companies who will work interprovincially. The CFIA is federal so they have limited jurisdiction when it comes to trade congress within provinces, but certainly have the right to apply for licenses when food crosses borders,” said Gary Gnirss, food labelling and regulatory affairs specialists at Legal Suites. “In doing so, they will have a better idea on a large scale of products that are being brought into the country and being moved across borders. They will then have a profile of the industry, they can then gear their inspection and auditing services to companies.”

With the new licencing program coming into effect July 2020, products can be sold across borders with one governing agency. Through this new program, the federal government will be able to track products that are being moved across provincial borders and what products are being brought into the country.

“What these companies will have to deal with when they’re going to be selling interprovincially is they’re going to have to come up with preventive controls and the manufacturer of food is going to have to have a control plan, which incorporates recall and what happens if you make a recall. Basically, the concept of preventive controls is to try to eliminate problems before they start,” said Gnirss.

Through this, the CFIA can now concentrate their resources on the biggest risk categories and vulnerable parts of the industry. Regardless of the product, processors have to abide by federal health and safety regulations.

During the manufacturing process, the manufacturer can be creative with the product flavour and recipe, said Gnirss. Certain food additives and vitamins are not permitted, so while there is flexibility in the formula everything throughout the process is food-grade safe.

Methods used to make kombucha and cold brew were not intended to produce drinks on a mass scale, but manufacturers have found safe methods to create their products for consumers while abiding by Canadian safety standards. Rules and regulations are being adapted to keep up with the ever-changing demand of new products. Manufacturers should be aware of any changes to regulations or seek professional help whenever they are in doubt. 

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