Is it possible to have a recall for the presence of stones in bags of retail dried beans?
The USDA standard for Blackeye beans has a maximum percentage limit for stones of 0.2 percent for US No. 1. This standard does not mean that every 1 pound package of Blackeye beans will have 0.2 percent of stones. But it does provide an allowance for the presence of stones. When and can you start using the FDA guidance on foreign material size relative to the risk of injury e.g. choking or broken teeth? Or does the FDA guidance document makes sense for broken teeth? Very small stones can chip and break teeth.
What if the dried beans would be used in a can of beans with ham? Would the expectations for the presence of stones change for the processor and customer?
Could the stone allowance be thought of as similar to the Defect Action Limits for insect fragments and rodent hairs? You can have a little bit of contamination but not too much? Could this idea be a stretch even more? For example, for allergens such as peanuts, a processor can label their products with the “may contains” language. “May contain stones and other foreign material” would probably not be a great sales idea. There is also the FSMA regulatory that requires the processor to notify the customer of any uncontrolled hazard.
When would you make a decision to improve your process for stone removal if you are below the USDA allowable stone limit for stones? Customer Complaint data could be a huge driver to provide the reason to make an improvement, but the online data from processing the dried beans should give real time data for improvement.
Potentially, the online data may not reflect the actual customer experience with stone discovery. The customer is 100% inspecting the beans through chewing each one. A food safety manager would need to consider whether or not the customer complaints reflect reality, there is a belief that only 1 out of 10 people actually make a complaint. I would believe that this percent would be even lower since most packages of retail beans and online instructions for bean cooking include the need to sort out stones prior to cooking.
Those customers who actually break a tooth may be the only ones that complain.
So, if you do find a lot of dried beans in your warehouse that exceed the USDA stone limits after reviewing the food safety online data, what do you do? Rerun the dried beans to remove more stones? A good review of the process line’s ability to remove stones to a lower level would have to be done prior to reworking the dried beans. At some point, an investigation into enhanced stone removal equipment needs to be done if necessary. Blend the affected lot of dried beans with another lot of dried beans with a much lower presence of stones?
So, with all the allowances and instructions for stones in dried beans, when would you recall the retail dried beans?