Will lead soldered pans pass inspection [Archive]

happy thoughts

12-27-2012, 08:35 AM

Will lead soldered pans pass inspection? I am pretty sure mine are lead free solder but I am not sure. And Is it "legal" to use food grade icing buckets from a bakery to draw off syrup into? I need the laws for PA.

I don't sell my syrup but looked into the PA laws last year to see what I needed to do to set up a commercial operation. PA has pretty much gone to the federal codes contained in the food safety act from what it looks like to me. Here's what the Ag ext. sent me last year. You should be able to find more existing codes from the citations within the following. Or just ask your inspector. You could also try emailing the PSU maple program. Their website is here: http://extension.psu.edu/maple-syrup

Reusing food buckets for syrup looks like it's a nono if you're selling from them since containers used for sale need to be single use. If you're just storing for later rebottling then I'm not sure. I don't think the bucket plastic should be a problem since it's the same material plastic jugs are made from. Where it might fall out is on the reuse issue.

MAPLE SYRUP OPERATION GUIDELINES
PENNSYLVANIA DEPARTMENT OF AGRICULTURE
13410 DUNHAM ROAD, MEADVILLE, PA 16335
(814) 332-6890

(FOR REFERENCE ONLY)

PURPOSE: to provide practical guidelines for the sanitary production and proper labeling of maple syrup and its by-products, and to ensure adherence to the Pennsylvania Food Law (Act #70); Chapter 46 (Pennsylvania Food Code); and 21 CFR 110
(Food and Drug Administration Good Manufacturing Practices), as applicable.

CHAPTER 46.201 (PA FOOD CODE): “Food shall be safe, unadulterated and…honestly presented.”
21 CFR 110.35 (FDA GOOD MANUFACTURING PRACTICES): “Buildings, fixtures, and other physical facilities of the plant shall be maintained in a sanitary condition and shall be kept in repair sufficient to prevent food from becoming adulterated within the meaning of this act. Cleaning and sanitizing of utensils and equipment shall be conducted in a manner that protects against contamination of food, food-contact surfaces, or food packaging materials.”

(In the case of facilities that produce at one site and finish/bottle/manufacture at another location, the following requirements shall apply as appropriate. The finishing/bottling/manufacturing location is an extension of the evaporation area, and is subject to inspection and these requirements. If done at a separate site, it is the responsibility of the operator to inform the inspecting Sanitarian of this arrangement for inspection purposes. If performed in a home, the home shall be inspected, and these operations shall be kept separate from home kitchen use.)

1. PHYSICAL STRUCTURE OF FACILITY: floors, walls, and ceilings shall be kept in good repair and adequately cleaned. Every practical precaution shall be taken to exclude birds, insects, rodents, and other vermin and animals from the premises of the operations.
2. SANITATION: an effective cleaning schedule shall be maintained at all times to maintain the integrity of the products. All equipment and utensils used in processing or handling of the product shall be maintained in good repair to assure lines shall be thoroughly cleaned with detergent followed with a sanitizer. Only food grade collection lines, buckets, holding tanks, etc. shall be used for sap/syrup storage/collection. Bottling, canning, and processing operations should be performed separately instead of directly from the evaporator.
3. WATER SUPPLY: all water shall be potable. Private water supplies shall be tested annually, immediately prior to the maple syrup season. Test results shall be available for examination upon inspection by this Department. An adequate potable hot and cold water supply shall be available and convenient to processing facilities for cleaning and handwashing purposes.

4. PEST CONTROL: the use of insecticides, rodenticides, and other pest control measures shall be permitted under such precautions and restrictions as will prevent the contamination of the product and ALWAYS according to label directions.
5. HYGIENIC PRACTICES: toilet facilities shall be available; all personnel shall wash hands after each visit to the toilet facility. Personnel shall not use tobacco in the facility or while in contact with food or equipment. Employees shall be free of communicable diseases and wear clean outer garments that will not contribute to the contamination of the product.
6. VENTILATION: all openings shall be properly screened. Provisions shall be made for condensate control during evaporation process.
7. LIGHTING: all facilities shall have sufficient light to permit efficient and effective operations. All lights located over food zones shall be protected against breakage which could result in product adulteration.
8. INGREDIENTS/ADDITIVES: all ingredients/additives from which food is fabricated shall be safe, suitable, food-grade, from approved sources, and used according to manufacturer’s directions, if applicable. Optional additives that may be used in maple syrup include salt, chemical preservatives, and/or defoaming agents. They must be declared within the ingredients statement if found above trace levels in the finished product and/or if the manufacturer’s directions indicate they must be declared.
9. MAPLE SYRUP BY-PRODUCTS: candy, creams, sugars, flavored maple products, and other miscellaneous products shall be made in an area where product contamination shall not result. Such products shall be handled according to good manufacturing practices, i.e., proper labeling, adequate packaging, sanitation, potable water, storage, etc.
10. RETAIL CONTAINERS: shall be single-service and properly cleaned before filling. It should not be assumed that new containers are clean when received from the distributor/manufacturer. Under no circumstances may containers be reused, unless they are returned to the original user.
11. STORAGE FACILITIES: shall be maintained clean and dry. All syrup and by-products that are not bottled or canned shall be adequately protected and covered to prevent contamination and/or adulteration. Products shall be stored off the floor and away from walls.
12. LABELING: all prepackaged syrup and by-products shall be labeled to show:
a) product name; b) name and address of the processor/distributor; c) net contents
d) additional ingredients. ANY additional labeling on the product must be
accurate and honestly presented in order not to be deemed misbranded.

OBJECTIVE: the elimination of adulteration/contamination: emphasis on adequate sanitary procedures to be included in the processing, bottling, canning, and storing of maple products; and complete, accurate labeling.

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you could also try phoning the pa dept of ag at the # contained in letter above.

Good luck and let us know what you found out.

happy thoughts

12-27-2012, 11:22 AM

Im not from Pa so I should not even post, but the Rossells wants to "draw-ff" syrup into these plastic buckets. Draw-off I assume means 219-222 degrees which is more than the 180-190 the plastic buckets are rated for. Yes canning temp (180-190) would probably be ok but not at draw-ff temps.

I have to agree with you if that's what he's asking. In that case, he could still draw off into something heat safe then fill the plastic pails at a safe temp. I'm still not sure whether reused buckets would be allowed for intermediate storage and later commercial repacking (and/or bulk sales) in PA . I think that's something he's*going to have to ask our Dept of Ag directly if another commercial producer from PA doesn't answer this.

As for the lead in a pan, you could always have the pan or syrup tested if the state has a question. If the test is done at a state certified lab that should answer it to the state's satisfaction. The lead issue is probably another question worth asking the county ext or state Ag dept if you don't get an answer here.

I know a lot of our state food laws have changed drastically in the last few years. There are lots more regs now that make it hard to start up a small commercial syrup operation without pouring a ton of $$$ into it. A few years ago there were virtually no laws for producers making less than $10,000 on syrup. Or at least that's what I seem to remember.

Our state has gone crazy for food safety. New laws on farmer's markets are ridiculous and put a lot of local markets out of business. I wanted to give a sprouter and some sprout seeds as a Christmas gift this year. I could find a sprouter but not the seeds for sprouting. From what I understand they're illegal to sell in PA now. A natural food store I went to just a few weeks ago told me the state inspector came in and made them remove them from the store shelves. I'm not entirely clear on the reasons behind this.