By Joe Heinzelmann
Raw material screening is an important part of 21 CFR 111. The current aspects of 21 CFR 111 do not put the burden of raw materials on the raw material manufacturer. The burden of the products from a compliance stand point lies within the manufacture of the product, and the brand holder. They do however have to follow 21 CFR 110, food processing cGMPs and are less stringent.
The testing requirements for dietary supplements and nutraceutical companies for raw materials under 21 CFR 111 is in sup part E, 111.75. Sup part E, section 75 states that one test must be completed to verify the identity of the compound before use. Before testing raw materials for microbial content, there are a few important considerations.
- Does the process using this raw material undergo a microbial reduction step?
- Does the screening cost (including holding time costs), outweigh the possibility of a rejected lot?
- Does the manufacture have a long standing record of providing materials within your critical limits?
- Are there antimicrobial properties of the ingredient? And will it be diluted when used in the final product formulation?
Setting specifications for raw materials will help determine if microbial testing should be completed before use. For example, if a product contains antimicrobial properties, and is diluted in a final product, the dilution of the anti-microbial properties could allow for microorganisms to grow. In this example, a lower specification could be used to screen out raw materials that would create problems to the final product when the antimicrobial properties are diluted.
Once limits and testing regimes have been determined for raw materials, another critical aspect to consider are the implications on the manufacturing process and the supply chain. If adding new testing points for total aerobic count (TAC), and yeast and mold (TYM), considerable time can be added to the entirety of the process.
When considering the supply chain of raw materials, and the manufacturing process, the total test time for total aerobic count, and total yeast and molds is critical. Adding 5-7 days of testing time on raw materials can be detrimental for manufacturing, and ruin just-in-time inventory practices. The BioLumix system allows for additional microbial testing controls, without the burden of long wait times.
The BioLumix system comes with a validation book, which helps provide users and auditors the needed data to show that the system is compliant and validated. Additionally, the BioLumix system can be validated against USP standards following the USP <1223> requirements.
For additional references, Michael McGuffin, President of the American Herbal Products Association, provided a useful overview of 111 compliance at a recent seminar. NSF provides training resources and support through their Dietary Supplement and Sports Nutrition groups.