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Re: Pres46 post# 52857

Thursday, 09/18/2014 9:21:03 AM

Thursday, September 18, 2014 9:21:03 AM

Post# of 70041
In the quest for factual information on licensing, lets take a closer look. As far as the licensing timing you questioned, again I say it looks like a misunderstanding either in the questioning or the answering or both. They are currently licensed in GA for business which was updated Apr 29th.

As far as the Dept of AG, yes the initial application is very simple to fill out. Here is a copy of it:
http://agr.georgia.gov//Data/Sites/1/media/ag_consumerprotection/administration/files/foodsafetylicenseapplication.pdf

Yes that in itself doesn't take long. However that is just the initial application. Lets look at the rules regulations of what must occur for licensing: http://agr.georgia.gov/Data/Sites/1/media/ag_consumerprotection/administration/files/guidelinesforcommunitykitchens.pdf
Guidelines for manufacturing in a Community Kitchen:

Is it surprising that foods usually prepared for immediate consumption may need significant changes to be successfully preserved and sold? This is the reality of food processing.
Community kitchens may have many requirements that you will have to meet, including:
? The food laws and regulations applicable to your specific product based on whose jurisdiction your product falls
? How you plan to demonstrate and document your product is safe from raw material acquisition through distribution
? Your customer base and risks associated with those particular demographic groups
? Whether you have had adequate process-related training or prior experience in food safety
? The risks and hazards involved in producing your particular product
? Inherent risks associated with foods in general, i.e. allergens
? How you plan to insure and demonstrate the safety and quality of your ingredients and packaging supplies being provided by your suppliers
? Whether your product requires additional temperature control after processing
? What your food product label is required to identify
? Whether your food packaging is appropriate to protect against post-process contamination
? What you would do in the event of a worst-case scenario, i.e. you produce a food contaminated with a pathogen



Then there are the Basic Regulatory Guidelines for Licensing:
http://agr.georgia.gov//Data/Sites/1/media/ag_consumerprotection/administration/files/basicregulatoryrequirements.pdf

This document is intended to be a “Guideline” which describes in simple terms a number of basic requirements which must be met before licensing food firms. For further assistance, contact the District Office in your area – please see page 4. Out of State inquires may contact the Administrative Office in Atlanta.

INSPECTION:
Inspections shall be conducted as often as the Department deems necessary to insure compliance with these regulations and at a minimum established by Departmental directives.
ADDITIONAL REGULATIONS:
Additional regulations may apply based on the type(s) of food operations conducted at the establishment.



Well lets just say this next one is a bit, actually a lot more involved: http://agr.georgia.gov/Data/Sites/1/media/ag_consumerprotection/administration/files/additionalregulationsapplicabletoprocessingplants40-7-18.pdf
ADDITIONAL RULES AND REGULATIONS FOR A PROCEESSING PLANT Please look closely at section 40-7-18-.09 Written Food Safety Plan

“HACCP Plan” means a written document that delineates the formal procedures for following the Hazard Analysis and CRITICAL CONTROL POINT (HACCP) principals developed by the National Advisory Committee on Microbiological Criteria for Foods.

(1) Each written Food Safety Plan shall be submitted to the DEPARTMENT for review. If an operator of a FOOD PROCESSING PLANT, in its discretion, submits to the DEPARTMENT a written food safety plan for such plant and such plan conforms to rules and regulations then such FOOD PROCESSING PLANT shall comply with the requirements of such written food safety plan including, but not limited to, any test regimen provided by such plan, in lieu of complying with a test regimen as specified under 40-7-18-.06.

Regarding Testing
(1) The COMMISSIONER shall require testing of finished products leaving the food processing facility, including ingredients going to other facilities for use in other products, for the presence of POISONOUS OR DELETERIOUS SUBSTANCES or other contaminants rendering such FOODS or ingredients injurious to health; testing shall be conducted according to the RISK category of the FOOD PROCESSING PLANT.



Now there is also the issue of labeling and approval with the USDA: http://www.fsis.usda.gov/wps/portal/fsis/topics/regulatory-compliance/labeling


Also the basic Food Safety Rules required if one cares to read through it all. http://agr.georgia.gov//Data/Sites/1/media/ag_consumerprotection/administration/files/generalrules40-7-1.pdf

Did you ever think that if they did install all of the equipment that they would not work on getting licensed to use it?
It is over $100k worth of equipment as was mentioned:

As PREP's anchor tenant, Harvest Soul has upgraded its dedicated production space well beyond "move-in" specifications, including significant electrical upgrades to provide improved processing. Other facility equipment includes:
-- Commercial Juice Press and Grinder - allows the company to freshly squeeze or press juices.
-- Commercial Blender - large capacity 100-gallon blender, with custom electrical support to allow for flexibility in a variety of speeds.
-- Control Panel - designed to spec, the panel provides the ultimate in automation, leading to tighter controls within each blend.
-- Double-headed Piston Filler - for easy "perfect fill" every time.
-- Capper - bottle capping unit, utilizing compressed air.
-- Positive Displacement Pump - food grade stainless steel pump to move viscous product from tank to tank.
-- Clean-In-Place Tank (CIP) - designed to ensure mandatory sanitation practices are more efficient and cost effective; will utilize only food grade cleaning supplies.
-- Centrifugal Pump - ensures complete clean-out of system for flavor change-over, reducing the process by more than 75% vs. alternatives.
-- Dedicated Cooler - allows for 100% organic ingredients to remain completely segregated.
-- High Capacity - production facility is near completion, and capable of producing millions of bottles per year.



The process of getting approval is not a quick one and can take time. A vendor must satisfy all of the requests the Dept throws at them which includes facility, processing, storage, procedures, product and testings etc.... There is no defined timeline in the processing of the application as approval is received once all aspects are approved by the Dept of AG. Really only the parties involved in getting licensed know the timeline as they know all the specific requests and requirements made by the regulators.

Again all this is just my opinion and DD on the subject of licensing and I encourage anyone else to dig into as well!



If you haven't learned yet, most posts on a message board are in the writer's opinion. All of my posts are in my opinion (IMO)......do your Due Diligence (DD) and make up your own mind!

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