Pursuing Quality in our Coffee Shops

Updated: Oct 13, 2021


In our first podcast, I told you about the need for the coffee industry to comply with the agencies that regulate it. At least in Puerto Rico, we could say that both the Federal Department of Agriculture and the Food and Drug Control Agency, known by its acronym in English as FDA, have independence in everything related to the manufacture, packaging, and storage of coffee. As specified in section 415 of the Food, Drug, & Cosmetic Act, we could say that this section applies to all those registered companies that have operations in both the production and roasting of coffee. But, in my understanding, this does not impede our coffee shops from moving toward meeting the expectations of regulatory agencies and treating coffee like any other product we eat.


Although coffee shops are not directly required to comply with many of these requirements imposed by the FDA, it is crucial to understand that every coffee shop must strive to provide a safe and quality product for its customers. In my understanding, this is where the established regulations apply to all those who are dedicated to serving this exquisite drink. That is why without going into details of other government entities that regulate this industry, I would like to present some ideas so that our coffee shops are in compliance and can at the same time introduce quality in everything they do. On a future occasion, we will go into more detail on how we can introduce quality from the manufacture of coffee, but our objective with this second episode is to understand how coffee shops can move towards compliance and maintain a quality standard in their products.


The Puerto Rico Department of Health plays an essential role in enforcing those establishments where food is sold, do so safely for customers, but sometimes it does not enter into those specific plans that ensure coffee shops consistently comply with these requirements. This is where coffee shops can take advantage and establish the necessary controls to achieve compliance with existing regulations and possible future changes.


I want to stop for a moment and make a parenthesis. Maybe you are thinking Andrés, this is very complicated, my business is very small, and I don't have time to establish these mechanisms, or perhaps you understand that your thing is to sell coffee and generate profits. Let me tell you that I have heard countless times these statements from companies dedicated to the manufacture of pharmaceutical products, and unfortunately, most of them have received citations from the FDA stopping the manufacture of their products and even forcing them to carry out the collection of the product already in the market, causing them significant monetary losses and credibility with the public that consumes their products. This is why it would be very convenient for coffee shops to make an effort to establish the necessary controls to comply with the imposed regulations.


I would like to at least explain some of these regulatory requirements and how coffee shops can begin to meet them. As I mentioned before, many of the existing regulations apply primarily to the previous stages in coffee processing (planting, collection, packaging, roasting, etc.) and not directly to coffee shops. However, I understand that coffee shops have a tremendous opportunity to demonstrate how they have matured compliance with established laws.


On January 4, 2011, President Obama signed this law to ensure that the food supply in the United States is safe (Food Safety Modernization Act (FSMA)), carrying out a change in the approach of responding to problems that had occurred in the past related to the safety of food products. This represented a significant change to the laws regulating food in the United States, which had not been revised since 1938. In addition, this law once again brought to the fore the responsibility that all businesses have in complying with them.


One of the areas where coffee shops could introduce quality is trying to develop mechanisms that promote compliance with everything related to good sanitary practices and the design of processes that promote it.


In Section 21 of the Federal Code of Regulations (21 CFR Federal Code of Regulations), there are some guidelines that coffee shops could use and adapt to begin to raise their standards of quality in the product they serve. To my understanding, the following sections of the Code could be used for this purpose:


a. 110.10 Personal Hygiene

b. 110.35 Sanitary Operations

c. 110.37 Sanitary Facilities and Controls

d. 110.40 Equipment and Utensils


As I have mentioned previously, the regulations that apply to coffee shops are not as specific as those that process and roast coffee. Still, in my opinion, we must try to introduce controls in our coffee shops. For coffee shops, these sections of the Code represent the basis for a safe environment in food processing and a step towards improving the quality of the product served.


I would like to briefly explain the sections of this regulation that, in my opinion, could be used by coffee shops creating procedures that help them comply with them.


a. 110.10 Personal Hygiene - to maintain control of staff hygiene, the coffee shop must do the following:


i. Take the necessary measures to control employees who may be ill and represent a possible source of contamination where there is a reasonable possibility that food, food contact surfaces, or materials from which food is prepared will become contaminated,


ii. Ensure that all persons who work in direct contact with food, surfaces in contact with food must use the necessary means to protect themselves against possible contamination of food. For instance, the use of masks, gloves, hairnets, beard covers and avoid using garments that can fall into food.


b. 110.35 Sanitary Operations - to ensure that coffee shop operations are kept as sanitary as possible, we must pay attention to the following:


i. The physical facilities of the coffee shop will be kept in sanitary conditions and will be maintained in good repair to prevent the food from being adulterated within the meaning of the law.


ii. Cleaning and sanitizing utensils and equipment should be done in a way that protects against contamination from food, food contact surfaces, or food packaging materials.


iii. Cleaning detergents and disinfectant agents used in cleaning and disinfection must be free of undesirable microorganisms and must be safe and adequate under the conditions of use.


iv. Toxic cleaning compounds and sanitizing agents should be identified, retained, and stored in a manner that protects food-contact surfaces from contamination.


v. Effective measures must be taken to exclude pests from processing areas and protect against food contamination in the facility by pests. The use of insecticides or rodenticides is allowed only under precautions and restrictions that will protect against contamination of food, food-contact surfaces, and food packaging materials. All food contact surfaces, including utensils and any food contact equipment surfaces, should be cleaned as often as necessary to protect against food contamination.


vii. Single-service items (such as single-use utensils, paper cups, and paper towels) must be stored in appropriate containers and must be handled, dispensed, used, and disposed of in a manner that protects against contamination from food or surfaces in contact with food.


c. 110.37 Sanitary Facilities and Controls - Each coffee shop must be equipped with adequate sanitary facilities and accommodations that include, among others:


i. Water supply: The water supply must be sufficient for the intended operations and must be derived from a suitable source.


ii. Drains: Provide adequate floor drainage in all areas where floors are subject to flood-type cleaning or where normal operations release or discharge water or other liquid debris onto the floor.


iii. Maintenance: Keep the facilities in good condition at all times.


iv. Washing: Facilities to wash hands and, where appropriate, to disinfect hands. Good sanitary practices require that employees wash and/or disinfect their hands when required by the operation.


d. 110.40 Equipment and Utensils - The equipment used must comply with at least the following:


i. Equipment should be installed and maintained in such a way as to facilitate the cleaning of the equipment and all adjacent spaces. In addition, food contact surfaces must be resistant to corrosion when in contact with food.


I want to emphasize that what is presented here tries to provide some general guidelines. For details of the regulation, go to the following address:


https://www.govinfo.gov/content/pkg/CFR-2013-title21-vol2/pdf/CFR-2013-title21-vol2-part110.pdf


Again, I invite you to visit our page and leave any comments or questions on the subject.


Andrés Escobar

Web-master