Join us at the Expert Review Panel on Ethanol Testing for Kombucha at the AOAC’s 131’st Annual Meeting taking place at the Atlanta Marriott on Sunday September 24th from 1-4pm. The meeting is free for all to attend.
KBI President, Hannah Crum, will be on the panel. KBI Secretary, Melanie Wade (Golda Kombucha), along with Claire Irie of Lupa’s Kitchen and Adina Martinez of Mighty Bucha will also be in attendance and will be bringing Kombucha to share with the panel.
On February 2nd, 2016, Hannah Crum, KBI President, met with several members of the TTB (Alcohol Tax and Trade Bureau) to discuss the trace amounts of ethanol naturally produced by the kombucha fermentation process and what steps the industry is taking to ensure companies remain in compliance of the current legal threshold for taxation of .5% ABV (alcohol by volume). Talking points included discussing the agency’s desire for the industry to self-regulate, the ethanol testing standard being developed with the AOAC, and an informative discussion on the numerous techniques utilized by the industry to reduce alcohol in addition to refrigeration.
The hour-long meeting was yet another step in establishing a closer relationship with the TTB in light of the letters that were sent to a handful of KBI members in 2015. Since kombucha is not intended as an alcoholic product, the TTB stated that it has no desire to regulate kombucha and prefers that the industry do so on its own. KBI agreed that self-regulation, just as in every other industry, would be the best way to reduce potential mislabeling and product quality concerns. To that end, KBI has already developed a set of Best Practices for all kombucha brewers that relate not only to alcohol testing but also to sanitary and business practices.
While the TTB is a partner in the AOAC process, it also reiterated that its participation in the consensus-based standards development process did not guarantee adoption of the new testing standard once fully vetted. The TTB maintained that its current testing methods (distillation and densitometry), which have been in use for over 100 years and are used to test the ethanol content of all kinds of products including foods, additives and other ingredients, are sufficient for detecting even low levels of ethanol. However, the TTB representatives also acknowledged that any other testing method may also be utilized provided it is validated. KBI has submitted the current approved testing methodology with validation to the TTB.
TTB staff were glad to learn of the several techniques already utilized by the industry for controlling ethanol production in kombucha. These include filtration, dilution, culture selection based on organisms, and aeration in addition to insisting on cold storage throughout the supply chain handling. Moreover, kombucha often contains similar amounts of ethanol to juice, sodas, and energy drinks, especially in light of the fact that the flavorings for these products are often in an alcohol-based carrier.
Overall, the meeting was a huge success and confirmed that both the TTB and the kombucha industry have the same goals – safe, compliant products that adhere to Best Practices. After the meeting, several TTB staff offered assistance to KBI and the kombucha industry as we continue to develop appropriate controls and protocols while determining what methods of testing will provide accurate and repeatable results. With the measures KBI is taking both with AOAC and the Verification program, we are on the path of self-regulation.
On Sunday, September 27th, KBI president Hannah Crum and and Heath-Ade CEO Daina Trout, head of LGO committee (Special Projects Team) presented to the Stakeholder Panel on Strategic Food Analytical Methods (SPSFAM) at the annual conference of the Association of Official Analytical Chemists (AOAC) to establish a new Working Group with the aim of developing a new testing standard for the low levels of ethanol in kombucha. Experts across various industries specializing in manufacturing, food chemistry, and laboratories were present as well as representatives from government organizations like the TTB.
Hannah and Daina shared with those in attendance the explosive growth in the kombucha industry while enumerating the difficulties with the testing methods in use by regulators in the US today. The message was clear: currently, an accurate, standard method of testing that takes into consideration the complexities of kombucha such as the strands of living culture, yeast bodies, organic acids, low pH and other factors simply does not exist. The Q & A was lively with questions, support and enthusiasm from the audience for this fascinating scientific problem and very much echoed that current methodologies need to be revised.
The stakeholder panel eagerly took up the process of formulating a Fitness for Purpose (FOP) statement. The FOP is ultimately the parameters that the Working Group will establish before sending out a request for methods to the international membership.
Fitness for Purpose statement: Methods need to accurately and precisely measure the ethanol concentrations to comply with alcohol and non-alcohol declarations in Kombucha in-process and finished products.
The Working Group will now proceed under co-chairs Hannah Crum and Sam Labonia of Cornerstone Labs. The goal is to hone in on the issues that will be necessary to take into consideration for determining accurate testing methods. KBI anticipates presenting the Standard Method Performance Requirements (SMPR®) to the SPSFAM Panel at the AOAC Midyear Meeting in March 2016 in Maryland. Since AOAC standards are in use by governments around the world, including the US, the TTB (Tax & Trade Bureau) has also been invited to participate in the process and are members of the Stakeholder Panel that will vote to determine the ultimate methodology that is selected.
The reaction from not only the stakeholders, but the general AOAC attendees was overwhelmingly positive and enthusiastic about the direction of this research. Not only was the presentation very well received, the questions asked after were informed and thought-provoking. Overall, KBI is thrilled to get the opportunity to work with the AOAC to find a method of testing ethanol in kombucha that produces accurate, consistent, repeatable results. “The AOAC is pleased to be working with the kombucha industry, regulatory bodies, and other stakeholders to develop such a standard,” stated E. James Bradford, Ph.D., Executive Director of AOAC International.
The working group meets regularly (biweekly) to refine definitions and identify criteria for the SMPR®