EHO, pests & fruit storage
Gethin ap Dafydd
I've been making cider as a hobby and selling it to local pubs and
shops here in Pembrokeshire, west Wales for the last 7 years. I was
making the cider in a small garden shed for many years but recently
relocated it all to an old WW2 airfield building. I had Environmental
Health visit me about 2 years ago when I was still at the shed but the
EHO phoned me last week asking for a revisit. After his visit on
tuesday he informed me that he found traces of rats and mice in the
building and told me that I have two weeks to carry out building work
for pestproofing, put down traps and poison for the pests and move the
fruit I have left unpressed into another pest proof building or they
will take me to court!
I was obviously shocked to find out that there are traces of pests as
we've never seen any there so will have to carry out the work to
pestproof the building. But I think some of the EHO's requests are
far fetched ie painting all the walls a food grade paint, replacing my
wooden sorting rack for stainless steel or plastic and storing my
fruit in a sealed pestproof location, not out in the open. All
cidermakers I know in Monmouthshire, Herefordshire and Somerset store
their fruit outdoors with no problem.
The more I spoke to my EHO the more I realised that he had no idea
what the process of traditional cidermaking is, he seems to think that
Im producing apple juice! I wash all of my fruit and I sterilise all
my equipment before cidermaking so I personally see my cider as a very
low risk product when it comes to food safety. I could do with some
guidelines that other cidermaker adhere to in order to educate my EHO
in how cider has traditionally been made and to prove that its never
caused any harm.
Ive looked on this cider workshop and saw that Andrew wrote that the
fermentation of cider kills off any Salmonella or E.Coli that pests
could carry onto fruit/equipment. Would anybody know if this is true
for any of the other nasties that pests carry such as Weil's disease,
Hantavirus or toxoplasmosis? Where can I get hold of official
documentation to get this in writing?
Many thanks.
Gethin.
Gethin's Cider, Haverfordwest, Pembrokeshire.
Andrew Lea
>
> The more I spoke to my EHO the more I realised that he had no idea
> what the process of traditional cidermaking is, he seems to think that
> Im producing apple juice!
This story seems to come up often outside of the traditional areas. Are
you a member of the Welsh Cider and Perry Society?
http://www.welshcider.co.uk/ They may have some advice.
Andrew
--
Wittenham Hill Cider Page
http://www.cider.org.uk
Gethin ap Dafydd
speak to you for advice.
Ive spoken to the NACM, EHO in Herefordshire and Somerset, the Food
Standards Agency who forwarded my query onto DEFRA, and Im really
struggling to get any consistent answers or any answers at all even.
Would you know where I could get hold of any documentation proving the
safety of fermented cider?
Of course I dont want any pests near my fruit or equipment so I must
rectify that problem but I do want to try to educate my EHO on
traditional cidermaking.
My HACCP covers many things but it doesnt help.
I dont see how storing my fruit outdoors under cover is any problem
seeing that they were picked off orchard floors anyway.
Many thanks.
Gethin.
On Jan 20, 5:30 pm, Andrew Lea <y...@cider.org.uk> wrote:
> On 20/01/2011 15:49, Gethin ap Dafydd wrote:
>
>
>
> > The more I spoke to my EHO the more I realised that he had no idea
> > what the process of traditional cidermaking is, he seems to think that
> > Im producing apple juice!
>
> This story seems to come up often outside of the traditional areas. Are
Andrew Lea
> Hi Andrew. Yes I am a member of the WPCS, Dave Matthews suggested to
> speak to you for advice.
> Ive spoken to the NACM, EHO in Herefordshire and Somerset, the Food
> Standards Agency who forwarded my query onto DEFRA, and Im really
> struggling to get any consistent answers or any answers at all even.
> Would you know where I could get hold of any documentation proving the
> safety of fermented cider?
>
a set of procedures to minimise food production risk. However, it
happens that there is good published data on the survival / death of E
coli and salmonella in cider which is generally taken to mean that those
pathogens are not an issue in fermented cider. I sent this all to Dave
last year.
I don't know of any data to show that rat-borne infections are destroyed
by cider although I would guess that they might be - if you think about
it, it would have been a pretty bizarre piece of work to have done
specifically because it would imply that a person was tolerant of rats
crawling all over their apples. Rats are opportunists and if there is
other easier stuff they can feed on, they will. Personally I found that
simple chicken mesh protection over stored apples elevated above ground
was sufficient to keep them out where other food was available - I also
used (covered) bait boxes outdoors near to my apples. At very least you
should put some such protective measures in case. But I do not sell my
cider so I have never had a personal EHO visit.
There are two general problems here:
One is that the whole Food Safety landscape has changed hugely in the
last 20 years. Issues like E coli 0157H and BSE and attributable
consumer deaths have forced EHO's to become much more vigilant, not just
because new legislation demands it but also because they have been
criticised at inquests and enquiries for not being more pro-active and
for falling down on the job. I think a lot of cider makers, seeing
themselves as rural craftsmen, have not caught up with these changes and
the fact that in law they are food production businesses now bound and
ruled like all others. What worked even in the 1980's does not work now.
But against that is the fact that cider requires some form of
proportionality of approach. It is inherently low risk due to the
alcohol and the low pH of the product. It is not like meat or dairy.
Badly-made cider is very unlikely to kill a person. The EHO's in the
main production areas understand this and they know what is 'acceptable
practice' because the test of time has shown it to be so. But in new
areas the EHO's have nothing to fall back on, and they will start from
the viewpoint of generic 'best practice' for food production overall,
which is likely to be much more stringent.
None of this helps you now. Sadly you are looking for documentation that
does not, and never has, existed. My feeling is that a one or two page
semi-official briefing document on acceptable practice in small-scale
cidermaking for EHO's and other interested parties is long overdue. I
think this is something that the 3 regional associations should jointly
push for through the NACM to which they are affiliated. It will cost
money, because some professional will have to be paid to research and to
write it, but if it then carries the NACM endorsement it could be lodged
with the Food Standards Agency and EHO's as a "Code of Practice". Nick
Bradstock tells me that there may be as many as 500 small cidermakers in
the UK. If they all club together a few quid to prepare such a document,
it would be a good investment, I think.
Ray Blockley
> My feeling is that a one or two page semi-official briefing document on
> acceptable practice in small-scale cidermaking for EHO's and other
> interested parties is long overdue. I think this is something that the 3
> regional associations should jointly push for through the NACM to which
> they are affiliated. It will cost money, because some professional will
> have to be paid to research and to write it, but if it then carries the
> NACM endorsement it could be lodged with the Food Standards Agency and
> EHO's as a "Code of Practice". Nick Bradstock tells me that there may be
> as many as 500 small cidermakers in the UK. If they all club together a
> few quid to prepare such a document, it would be a good investment, I
> think.
I've been following this thread with great interest for a couple of reasons.
The first is that we also live in a 'historically' non-cider-making area and
the second being that I sympathise greatly with the concerns Gethin is
having, especially after drinking and enjoying his ciders at the Clytha.
Only a few years ago I was considering throwing the whole craft commercial
cider-making idea into touch after initial contacts with my EHO and TS folk;
some may remember that time and I remember it as a very black and depressing
time. However, we persevered and came through - though I still keep TS at
arms length and my wallet is still having nightmares!
The idea of such a document as Andrew is suggesting is, I feel, an excellent
one. We will then all have some evidence of what the problems - real or
not - are and hopefully a clear plan of how to overcome them; and of course
we will have a pukka document to refer EHO's and TS folk to. I'd be very
interested in seeing this idea taken further. If it costs me a few pounds to
contribute to this research, I'd consider it money well spent. Particularly
in light of the worries and headache that ill-informed EHO's and TS folk can
bring. I had to fork out plenty dollar to meet what the EHO's demanded, yet
experience shows that others have been passed with nothing akin to what
we've had to set up, while others again have had much more draconian
measures enforced.
In my travels around the UK visiting cider-makers I hear horror stories such
as that of EHO's demanding floor-to-ceiling 316 S/Steel, or emptying then
steam and pressure washing of all cider-making buildings (ceilings, walls
and all) on a 6-monthly or yearly cycle. We need some form of specification
that we can work to and use to fight our corners.
Bring it on.
Good luck, Gethin.
Cheers,
Ray.
http://hucknallciderco.blogspot.com/
http://torkardcider.moonfruit.com/
Tim
I need to inform them I am making Cider that will eventually be for sale, a
document I could quote from would be brilliant.
Tim in Dorset
Andrew wrote:
Bring it on.
Good luck, Gethin.
Cheers,
Ray.
http://hucknallciderco.blogspot.com/
http://torkardcider.moonfruit.com/
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chris harrison
David Llewellyn
quid towards your 'briefing document' if it were to be produced, in return
for a copy of it, to assist our own EHOs understand what they are dealing
with.
David Llewellyn
Tim
general production of Cider, he wanted to know where the apples came from,
were they washed before use, is it possible for any pests to walk over the
apples or equipment etc, what a nightmare this is going to be.
Tim in Dorset
David Llewellyn
--
Andrew Lea
>
>
> The idea of such a document as Andrew is suggesting is, I feel, an
> excellent one. We will then all have some evidence of what the problems
> - real or not - are and hopefully a clear plan of how to overcome them;
> and of course we will have a pukka document to refer EHO's and TS folk
> to. I'd be very interested in seeing this idea taken further. If it
> costs me a few pounds to contribute to this research, I'd consider it
> money well spent.
> Bring it on.
I think I'm right in saying that annual meeting for small cidermakers
with the NACM is coming up very soon. Those of you who are members of
one of the regional associations (as you should all be IMHO) will
doubtless have had the details. I suggest one of you aim to get it on
the Agenda or at least as AOB. Then the idea can have its first outing
and kick around.
BTW this shouldn't be seen as a plan to allow dirt and filth in through
the back door. Cider makers *are* food producers, no question. It's a
mater of being proportionate in the context of what is inherently a
low-risk food production process.
Nick Bradstock
second para.
I recall posting on this very point on previous occasions - and have, for
NACM, had discussions with FSA personnel over proper and proportionate
practice.
I've just searched for (and found, much to my amazement) the following
summary note of mine of a discussion with them in May2007 - see below -
which was agreed then as OK.
(apologies for those who may have seen this before and to my shorthand note
'Farm Cider')
In summary, there is cause to be scrupulously careful in handling edible
food crops (eg: apples for direct consumption as fruit or fresh-pressed
untreated juice) but a proportionately less stringent approach (but still
careful) to the handling of raw material for processing.
As far as orcharding is concerned, NACM is revising its 'Growing Cider
Apples' handbook (which is after all aimed at people with some knowledge
already of procedures) but the entry on grazing, etc, remains the same and
as indicated below.
To write a handbook on EH matters would be a major task and require a
specialist author (Andrew?) - clearly if there's a demand for such a thing
then NACM would consider it but I have to say that such matters are usually
for individual members to equip themselves and NACM itself can only provide
an overview and advise of changing official attitudes, new regs etc.
The NACM day Andrew refers to is on 10/02/11 at Westons (so there probably
won't be too much interest in it?) and attendance, if you do wish to explore
the possibility, is free but as a member of SWECA, TCC&PA or the WC&PS.
All the best
Nick
General:
- No cases known that might give cause for concern.
- US-style 'cider' and fresh apple / pear juice are a very different
matter and should at least be filtered and/or pasteurised before consumption
(FSA aware).
Specific:
The UK cider making process inc. arrested fermentation and low-alcohol
ciders (includes pears/perry/pear cider):
1. Apples growing in the orchard - exposed to more (wild) animals, etc,
than just stock (and dogs) which are controlled as in the "Growing Cider
Apples" handbook (remove stock at least 56 days before harvest and dog
owners to take away dog faeces).
2. Apples picked up from the ground - exposed to soil contamination.
3. Apples washed in cider mill and generally inspected with worst
rots/damaged fruit removed.
4. Milling and pressing so that conditions are immediate exposure to pH
typically in the range 3.5 - 3.9.
5. Sulphiting, typically at 100 mg / litre as SO2 (legal max in
finished cider 200) depending on pH.
6. Fermentation over say 21 days, could be longer - strongly reductive
conditions with alcohol developing to at least 5% abv.
7. Maturation/storage - say another 21 days at ambient/cool
temperatures but possibly up to 300 days for farm cider.
8. Preparation for packaging - typically includes carbonation but with
some dissolved oxygen present and more sulphiting (ca. 50 mg/l).
9. Filtration - depth x 2 stage and typically to about 0.5 micron or
ultra-filtration to perhaps 0.1 micron or even below.
10. Pasteurization - continuous or in-pack (no spec given).
11. Warehousing - with final QC checks inc micro (for yeasts mainly, on
media suited to fungi but bacteria observable).
12. Relatively poor nutrient status of apple juice and cider - high
sugar perhaps but low nitrogen and low vitamin B1.
Notes:
For Farm Cider the process might stop at 7. For low-alcohol / arrested
fermentation cider, the means of achieving this are technically quite
intensive and carried out only in well-equipped and scientifically-literate
cider mills.
> Bring it on.
Andrew
Gethin ap Dafydd
off the same hymn sheet!
Good idea to bring it up at the NACM meeting.
I've got to agree with you Andrew, there's no way that Im trying to
get EHO to allow dirt and pests to contaminate the fruit/cider. My
pickers and pressers will tell you how obsessive I am about keeping my
cidermaking equipment clean and sterilised before every cidermaking
day. This was traditionally because I didn't sulphite due to my
sulphite allergy so had to make sure I kept out any nasties! This
year I've experimented with sulphiting, cultured yeast and keeving but
my standard of cleanliness hasnt changed. Unfortunately I dont live
near the premises I make cider at so its difficult to keep an eye on
it between weekends. My nets of fruit are stored on a galv mesh cage,
3 foot off the floor with a polytarp over them all to stop any birds.
I just thought it was erRATic and irRATional of my EHO to give me 2
weeks (4 days as I only have the weekends) to pestproof the building
even though I have ceased production this year until october! He said
he couldnt extend the duration as I still have foodstuffs on the
premises. Fermenting cider in plastic drums with airlocks fitted
seems like a very securely stored foodstuff to me. I have to conctete
up all holes in the building bigger than the thickness of a bic pen
which means I will have no airflow in the building at all. Bit of a
problem when I rely on natural airbourne yeast and have 300 gallons of
cider fermenting and producing lots of carbon dioxide gas which will
have no way of leaving the building now. At least any pests then will
suffer very bad headaches or even suffocation! Im required to fit
rubber door seals on the wooden door even though my EHO told me about
five minutes before than that rats and mice' teeth continually grow so
they will knaw at anything be it food or not!
If he does indeed take me to court, I cant think how he will win as I
only mover to the premises back in october so obviously havent sold
any of the cider or even drank any of it myself as it ist ready yet!
Im usually quite mild mannered but this has really RATtled my cage and
made me RATTY! I must be running a Mickey MOUSE operation!
CiderHead
I recently contacted my EHO here in Bristol (UK) and pointed out that
some of my apples come from an orchard that has cows grazing in it, so
the apples are rather cow-patty. I thought he would get a bit upset
about this but after I said I washed them just after collection, then
again just before pressing, he said that's fine. And nothing else was
required at all. No paints, grills, etc. Mind you, I've got no
clearance in writing so, if they decide to check again, the next EHO
may have a completely different ideas.
This really does need to be clarified on a more formal basis.
Perhaps we should all just phone the guy I spoke to!
Best of luck,
Martin
Jez Howat
EHO and have had a visit from TS last year.
Therefore, I have a couple of documents and a HACCP written out for my own
production which I hope to share with you... although for at least one of
them I need to go away and find out who gave it to me and ask their
permission.
Basically, when I initially spoke to them we agreed that they would go off
and research cider making (and speak to one of the cider making counties
EHO's). When we met, I gave them the document to which I adhere to, plus the
HACCP and the TS certificate ref patulin etc. Yes, even though they had
asked about it, patulin was still important to them... and he was very happy
that TS had been there first and tested it.
They took a look at my cider garage and gave it the OK as per the guidelines
I work to, and then asked if I could provide a one off document to show what
I do (as per the HACCP). The only other thing we discussed was working out
how we could agree on a cleaning schedule (document) that was not too
onerous, but would be sufficient to demonstrate that I do what I say I do.
The argument is that, even if I do a check list, it doesn't prove that I did
it - although not doing it leaves no defence at all.
Its only right to point out that I haven't had any kind of 'letter' from
them yet, so the situation could change.
I will post more later (am in Manchester with no access to the information I
require to post), and will probably want to send it to Andrew/Nick first for
their opinion. As it is to do with my business model I am not sure what
needs doing to make it universal (if it can be made universal), but at least
it would be a start.
All the best
Jez
Tim
between getting it right and getting it wrong.
Tim in Dorset
All the best
Jez
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