Scaling Up Your Food Business: Regulations and Considerations

- So thank you for joining us this afternoon for our first spring webinar in our Scaling Up Your Food Business series.

Today we're going to talk about Regulations and Considerations, a Pennsylvania Department of Agriculture Perspective.

And for that perspective, we have joining us Suzanne Pyle, who's a food safety program specialist with the Bureau of Food Safety and Laboratory Services.

I have just a few slides to quickly go through before I turn that over to Suzanne.

And the first here you can see on the screen this presentation is available in an alternative format if you would like.

So for instance, if you would like to have a PDF of the slides, you may request that and you may do so by contacting myself or Martin or or our colleague rep as well.

And our contact information will be on a slide that's coming up.

I don't believe there are any trade names mentioned in today's presentation, but if by chance there are, there's no discrimination intended or no endorsement by Penn State Extension is implied.

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If you have questions, we encourage you to please enter those into either the question and answer pod or the chat pod throughout the presentation and we will address those at the end.

And finally, at the conclusion of today's webinar, you will be directed to a short evaluation survey.

And when I say short, it truly is short.

So, please take a moment to complete those few questions that we have for you.

The information that you provide is very valuable to us in serving your needs as we move forward.

This is the university non-discrimination statement.

So, you may take a moment to review that.

I think I already did that slide, so we'll skip over that.

And next month, we encourage you to register for our webinar next month on Friday, March 17th, again at 1:00 PM, where we'll be discussing how to get started on digital traceability.

And I think we're all very excited about that presentation coming up.

We have a guest presenter who will be coming in to talk about how digital traceability can really benefit a food business as well as show some examples.

So, we encourage you to join us for that.

I think it'll be very, very interesting.

And finally, your host for this webinar series today and into the future, Martin Bucknavage, he's joined us on the webinar today.

He's a Senior Food Safety Extension Associate at Penn State.

And his email address is there and areas of expertise are there on a screen.

Also, Rick Kralj, a Food Safety and Quality Extension Educator.

And myself, Sarah Cornelisse, I'm a Senior Extension Associate with the university.

So, if you have any reason or questions, feel free to contact any one of us and we will do our best to assist you.

And with that, I will turn it over to Suzanne.

So, let's see here.

- [Suzanne] Okay, thank you Sarah and thank you Martin and Penn State Cooperative Extension for inviting me to speak to all of you today.

I'm hoping to go through some of the issues that we've encountered with firms as they scale up their small food business to take the next step.

And just to verify, I hope everybody can see my screen okay, and we'll get started.

So again, my goal today is to address the commonly encountered issues with taking the food business to the next level with emphasis on the following business models: From the farm to the production room.

From the retail food facility to the food manufacturer.

From the small processor to the big time and from the warehouse to food processing.

So with changes in this also can come changes in the requirements under the Food Safety Modernization Act, as well as licensing requirements with PDA.

So as I discussed the different types of models, a couple of things that are considerations across the board for the business.

You'll wanna consider space limitations, refrigeration limitations and space availability in them, staff limitations.

And there are some complicated processes that may require additional record keeping or lab testing, and we will touch upon those a little bit later.

Those can include fermented foods, acidified foods, low-acid canned foods, seafood items, jams and jellies.

So to start, I wanna start talking about from the restaurant to the processor because this is a fairly large jump for a lot of people and it tends to be kind of a normal progression when you have a key food item at your retail food facility that you wanna get out there for the public.

So to begin with, we'll talk a little about the registration requirements.

So for PDA, the Pennsylvania Department of Agriculture, if you are a retail food facility and you are making greater than 20% wholesale sales, we do require that you register as a food establishment with our department.

Now, if you are making under the 20% wholesale sales, you are still subject to good manufacturing practices, which we refer to as GMPs, as well as labeling requirements.

But the actual registration with PDA is not necessary unless you are making over 20% wholesale sales or as we'll talk about in a moment, there are some exceptions such as seafood, low-acid canned foods, acidified foods or juice has up.

So a couple of links that are included in this that I'll provide.

We have our food establishment application, that is our application that you would wanna complete as you make this step to the process or with greater than 20% of your sales as wholesale.

It requires a commercial facility, but in most cases, and we'll discuss this later as well, retail kitchens more often than not meet the requirements for a commercial food establishment kitchen as well.

Another thing to keep in mind as we move forward is also the potential need for a milk processing license.

We will talk about that a little bit later, but if you are producing foods that contain 50% or greater milk, that's more than likely the license that you're going to need to obtain.

And this license, our food establishment license covers online sales, wholesale sales in and outside of Pennsylvania.

So moving towards the FDA requirements, if you are making more than 50% of your sales, wholesale sales, the FDA recognizes you as a food establishment, and they do require facility registration on their website.

This would cover wholesale sales in and out of Pennsylvania.

Some exceptions to this would be seafood.

So regardless of whether it's greater than 50% sales or not, you would still need to register with FDA for seafood sales.

Additionally, low-acid canned foods and acidified foods require processing of the procedures regardless of the wholesale amount.

Continuing with the restaurant to the processor.

A little bit about equipment.

So typically the equipment proof for use in a retail environment is also acceptable for the processing environment.

These are some of the things that you would wanna keep in mind, quantity of production.

So can your current equipment that you use produce the quantities that you want as you're moving forward?

It may mean that you need to trade in a smaller model for a larger one.

Cleaning frequency.

The equipment that you're currently use, can it handle the frequent cleaning?

Is it easily cleanable?

And will you have the time availability to devote to tearing the equipment apart as needed?

Also, keep in mind you have adequate storage for a small processor or a small restaurant, you might have a set number of refrigerators, freezers, or dry storage space.

Keep in mind as you're scaling up, there may be a need for greater storage space in refrigerators, freezers, or that dry storage area.

There's also some limitations to the food prep area, such as can you devote that space during working hours?

It may require an adjustment so that the food processing end is done at off hours.

You'll also wanna ensure that while you're processing, that you're preventing cross-contamination.

This can be done by ensuring that you're cleaning food contact surfaces regularly, that you're storing chemicals separately, and also that you are being mindful of allergens in cleaning between allergen products.

You'll also wanna keep in mind whether or not you can devote the attention to the packaging and the labeling requirements while you're a functioning restaurant as well.

So a couple of things about labeling.

Some of the labeling requirements for retail and manufacturers can be different.

So essentially what we're looking for on labels for any processor would be the name of your facility, the common name of your food, the ingredients, including the sub ingredients.

So for example, if you have a chocolate chip cookie, we don't want you to just place chocolate chips as an ingredient.

We want to include the sub ingredients for those chocolate chips as well.

This is one of the major controls we have for allergens.

You'll also want to include on the label the address of your facility, net weight of contents, and possibly nutrition facts.

Something else to keep in mind is if your product contains greater than 2% meat, you may be subject to USDA registration and inspection.

There are some exemptions to this, but we do ask that if you are planning on producing a food product that's gonna have two more greater than 2% meat, that you do reach out to the USDA to ensure that you are either exempt from their inspection or that you are following their labeling guidelines.

And here you'll also see a link to some of the labeling requirements for USDA regulated products.

So as I touched upon earlier, if your product contains more than 50% milk, it will likely be regulated by our milk division.

Labeling for milk must be approved prior to production of the product.

It's also essential that the information on the labeling, it meets the requirements for dairy products that can be conducted.

Excuse me, a review of the label will be conducted by the PDA milk inspector, and you can find additional information on the labeling for milk products by contacting a PDA milk inspector or specialist.

And by reviewing the FDA labeling requirements.

So when do you need to include nutrition facts?

When the product enters commerce, if the product is intended for resale in the packaging that you are placing it in.

And there are some exemptions to nutrition fact labeling.

So you'll see that fewer than an average of a 100 full-time employees and fewer than a 100,000 units of products sold in the US will make you exempt from nutrition fact labeling.

So this is something to keep in mind if you are moving from a small business model to a larger business model, it may mean that you now need to encompass the nutrition fact information on your labeling.

Additionally, you'll also find that when trying to sell your product to larger wholesalers such as grocery stores or online retailers.

Quite often they are going to require nutrition fact labeling information regardless of whether or not you are exempt.

So a couple of things to keep in mind that you'll want to avoid when you are labeling your product.

You'll want to avoid making special claims such as intended to treat or cure.

Food items that have statements such as this are treated typically as either a nutritional supplement or a medicine by PDA as well as the FDA.

Another thing to be careful about would be dosing amounts.

So when we see dosing amounts on packaging, it often indicates that this is a medicine and as such, it does need to meet the requirements set forth by the Food and Drug Administration.

Neither nutritional supplements nor medicines are covered by Pennsylvania Department of Agriculture.

Those will all fall under the jurisdiction of the Food and Drug Administration.

You'll also wanna be careful of misleading statements such as less than reduced lowfat statements such as that.

There are specific labeling requirements if you are going to make claims like that.

And we do suggest that you reference the code of federal regulations for further details if you are interested in including statements like this on labeling.

You'll also wanna keep in mind that there are some products that have what we call standards of identity.

This means there's a definition, a written definition that identifies what this product is and it has specific specifications to meet that statement.

So if you are interested in labeling your products as jams or jellies, there are labeling, or excuse me, there are testing requirements for these products to ensure that they do meet the bricks requirement in addition to items like ice cream where we are looking for specific amount of milk fat.

Some additional things to keep in mind when it comes to labeling, these are not required, but they may be things that you wanna consider as you're moving your business from small to large scale.

So date marking, while we only enforce this for food manufacturers making baby formula and milk, it is a good idea to do a shelf stability study on your product just to ensure that your product on the line is not going to grow mold or that it is going to be dried out, things that would more often than not be a quality issue than a food safety issue.

Another thing to keep in mind is the use of barcodes or QR codes.

So some larger retail chains will require this of you, particularly barcodes.

QR codes as a reminder may not replace labeling requirements.

So I know that's a very common question we get.

People want to include QR codes on their product in lieu of some of the labeling requirements such as ingredients or nutrition facts.

There are some exemptions to these requirements in labeling depending on the size of the packaging, but more often than not, we would not permit the use of a barcode or QR code in glue of the appropriate labeling information.

Another thing to keep in mind as you're growing is the packaging that you'll be using as well as the delivery method.

So we wanna make sure that anytime you're packaging a food product that you have a food grade container.

If you're not sure about that, you can always reach out to the container manufacturer and ask for verification that it is approved for use and that it is food grade.

You also might wanna consider tamper-proof containers just to ensure that your product cannot be tampered with in the public and also decants.

So decants are increasingly being used as we see an increased number of people who are doing freeze drying in the state.

One thing that we do want to ensure is that they are approved for food contact.

And like with the food grade containers, you can always contact the manufacturer and more often than not, they'll be able to provide you with something in writing verifying that it is safe for food contact.

Something else to consider the delivery and the transportation of your products.

So keep in mind if your product requires refrigeration and you will be transporting large amounts of product, you may need to consider changes in the way that you transport them.

You'll also need to keep in mind, if you're sending products through the mail, do you have an appropriate mailer?

Is there a refrigerant being used in the mailer?

And will the mailer be able to maintain its integrity with the refrigerant that you plan on using?

You'll also wanna be sure that you have outlined who is responsible for the transport.

So if you are taking responsibility for transporting your products, you'll want to ensure that no cross-contamination occurs during the transport, you're maintaining the fleet and to ensure that delivery persons are knowledgeable about the basics of food safety.

So a couple of other things to keep in mind is that if you do have one transport vehicle and you have other products that you sell, you'll wanna ensure that your equipment is thoroughly cleaned and that no hazardous chemicals waste were transported prior to being transported food.

Taking into consideration a slightly different model, we have the small processor moving to a large processor.

So in these situations it could be you previously had a limited food establishment, which is our version of the the cottage food license in Pennsylvania, and maybe you're looking to move to a larger facility or produce larger amounts and just more space is needed.

So this would be similar to moving from your homestyle kitchen to a larger commercial kitchen.

And you'll wanna keep in mind there are some additional changes that may be needed.

So keep these things in mind as you're scaling up.

Equipment requirements.

A full food establishment license requires a commercial kitchen.

This can mean additional sinks, where previously with your limited food establishment license, you may have been permitted to use a homestyle single sink with the full food establishment license, you will need hand washing sinks, appropriate wear washing sinks, and mop and slop or floor drains depending on the type of situation and products that you're producing.

You'll also wanna ensure that you have grounds maintenance.

This means ensuring pests are not in or outside of the building.

Weeds are controlled around the building.

You'll wanna ensure that you have zoning and building code approval.

So you will run reach out to your municipality beforehand.

Another thing to keep in mind is building rental.

So keep an eye on what is your responsibility and what is the landlord's responsibility.

In some cases, if an inspector would to would find overgrown weeds, pooling of water in a parking area, outside of the processing rooms, those are things that you could be cited for on your inspection report.

So it's always a good idea to fully read the agreement that you have with the rental property or landlord to ensure that you have clearly defined your roles and their roles.

Another thing to keep in mind is people move into larger spaces.

In some cases these are shared facilities.

When you move to a shared facility, it is always a good idea to take a look at the agreement and be clear about what your responsibilities and the pricing will be ahead of time.

Some shared facilities run differently than others, some will make you responsible for portions of the payment of electric.

They may have limitations on time and space that you can use the facility.

So be sure that you fully review these things with the shared facility prior to any agreements being signed.

You'll also wanna ensure when you have these shared facilities, that you have a specific space to store your equipment, your ingredients, and your finished products separate from other people's.

This way you can avoid the potential for allergen cross-contamination or cross-contamination for any type of biologicals that might be present.

You'll also wanna consider space and ensure that facility has the appropriate space for you to store your product.

So in keeping with the small processor to the large processor, you'll wanna keep in mind as sales increase.

So do the responsibility.

The Food Safety Modernization Act requirements may change as your firm grows.

Here you'll see a link to 21 CFR 117, which outlines the requirements for manufacturers, processors, and warehouses.

Currently, if your food is processing food, or excuse me, currently, if your firm is processing food and has greater than 1 million in sale per year, which is adjusted for inflation currently to be $1.2 million in sales, you may need to register and meet the full PC requirements under 117.

So we did touch upon this a little bit earlier, but some foods are subject to additional regulations in addition to 117, or they may be subject to modified requirements.

Some examples of additional regulations would be juice, seafood, low-acid canned foods, and acidified foods.

So if you have that greater than 1.2 million in sales, some of the requirements that you'll need to keep in mind are that you must develop a food safety plan that includes elements such as recall plan, preventative controls, and includes a hazard analysis.

Additionally, with this expanded responsibility, you're required to conduct supplier verification.

In most cases have a PC trained individual, and there are additional record keeping requirements.

So I'm gonna switch gears a little bit and talk about from the warehouse to the processor.

So perhaps you have a warehouse and you are interested in adding some repacking or you're looking to do a little bit of food processing there on site.

So keep in mind that new activities may require new equipment and inspection.

So if you're going from a regular warehouse, you might wanna keep in mind with added equipment, there is an added cost.

So think about whether or not those value added products would be worth the investment.

Additionally, you'll wanna keep in mind, will you have the space in that warehouse to dedicate to food handling.

So we wanna ensure that if we are working with open food, that there's plenty of space to prevent any kind of cross-contamination, that any food allergens are being stored separate, and that you do have the ability to be able to clean those surfaces properly.

So question would be, should you contact PDA regarding the change in operation and the new layout?

And the answer is yes.

So while you may currently hold a food establishment license because you have a warehouse, additional product addition such as processing foods, repacking are going to require new equipment and reinspection by the department.

You would not need to apply for a new license in these situations, but you would need to notify your inspector directly to let them know that these changes are occurring.

Some additional considerations when you're adding food handling to what may have previously been a pre-packaged warehouse, you'll wanna consider the following items, you will need hand washing.

So you'll have to consider that plumbing that will need to be added to the area where you will now be handling the food, repacking the food, processing the food.

You'll also need that designated production space to avoid cross-contamination potential with other stock.

You'll need to ensure that you have appropriate wear washing for what kind of activities you plan on doing.

Additionally, you'll wanna ensure that the equipment you're using is properly designed.

So we're looking for easily cleanable scoops, knives, tables, and equipment.

You'll also wanna ensure that the floors, walls, and ceilings in this processing area are appropriate for what you're doing as well.

So typically we're also looking for easily cleanable surfaces for these as well, you'll wanna ensure that your lighting is shielded or shatterproof, and you'll wanna make sure that the floor, if previously was just concrete, is sealed, painted.

Our test is that we wanna ensure that if any kind of food was to splash that you could easily wipe it off that surface and at the same time prevent any gaps between floors and walls, things like that that pests could potentially get through.

Additionally, you'll also wanna keep in mind sanitation schedules and employee training.

So if you are looking to have your warehouse employees now move into the food processing world, you will need to give them additional training based on the types of foods that they will be handling as well as their roles in the processing.

So additionally, I wanna also talk about from the farm to the processor.

Quite often we get calls from licensed farms that are already selling produce and they're interested in potential additional licensing on their farm.

So different licenses may be required for different activities.

Some of the more frequent licenses that we see associated with these business models would be the milk license.

So this would be dairy items that contain greater than 50% milk ingredients.

This can be anything from a cheese dip to cheese itself, and of course milk or butter.

And then additionally on the farm, if the person in charge is looking to do some value added items and they are looking to use their homestyle kitchen for this purpose, we would ask you to look into our limited food establishment license.

This license allows people to use a homestyle kitchen for food preparation.

There are some things to keep in mind when it comes to the limited food establishment license, including one that we would only permit foods that at the end of processing are non TCS or do not require time or temperature control for safety.

So some of the more popular items would be some types of pickled goods, baked goods, things that do not require refrigeration after they're prepared, but would allow you to use maybe some extra produce or allow you to provide a few value added services along with your products.

If a facility is interested in having products, I'm getting ahead of myself.

So additionally, in addition to that limited food establishment, if you have a commercial kitchen on the farm that you are looking to use, we would license you with the food establishment license.

This one is specific to commercial kitchens and it does allow for the production of foods that require time and temperature control or TCS foods.

Additionally, you may require a retail license if you are looking to open a general farm store, sell at farmer's markets or have a point of sale where you're selling at.

So let's talk about a couple of the situations where you would wanna contact the Pennsylvania Department of Agriculture regarding scaling up that business.

So one, anytime a facility relocates, even if it's across the street, if it is a different street address, you will want to notify us.

These licenses that we issue are based on the physical address of the facility.

So these licenses are non-transferable between locations and we do need to come out and inspect the new location to ensure that it meets all of the requirements set forth in our federal regulations.

Additionally, major remodels, such as the expansion or layout changes that we discuss, such as with a warehouse, will warrant a new inspection if you already hold a food establishment license through the Pennsylvania Department of Agriculture as a warehouse, no additional licensing would be required in this situation, but it would warrant that an inspector come out to evaluate the process that you intend to follow through on, as well as the setup that you have where you'll be conducting that process.

Additionally, a new license would be required if you add a new FE or LFE license.

So if you previously had a retail food facility and you're now looking to wholesale greater than 20% of your products, we would want you to apply for more than likely the food establishment license.

Additionally, changes of ownership.

So our licenses are not only non-transferable between locations, but they're additionally non-transferable between owners.

So if there is a change of ownership or you're purchasing another business from someone, then you will want to apply for a change of ownership license change through Pennsylvania Department of Agriculture.

Once we receive that notification that there's been a change of ownership, we'll call the operator to schedule an opening inspection so that we can fill out the appropriate paperwork for the change of ownership, discuss the foods that you may wanna be producing, and any potential changes that might take place at the location.

Additionally, it's always a good idea to notify your inspector if you are looking to add new products.

As previously mentioned, there are some food products that require testing, whether it's for a standard of identities such as with jams and jellies, to verify that you're meeting the legal definition of those foods.

Or if you're looking to add pickled items, we may be requiring that a processing authority review your process or even that you register that scheduled process with the FDA.

So whenever you're adding new products, it's always a good idea to reach out to your inspector.

In some cases, what you may have thought was a shelf stable product that was non TCS may actually require either testing to verify that or it does require refrigeration.

So please keep in mind your inspector is a great resource as well as the specialists that work for the Pennsylvania Department of Agriculture.

We're all here to help and we all love to see our businesses succeed in Pennsylvania.

So please always feel free to reach out to us if you have any questions or you're unsure.

And thank you for the opportunity to speak to all of you today.

Are there any questions?

- Excuse me. Yeah, I have, oh, sorry, go ahead, Martin.

- Yeah, I have a question off and when you went through the nutritionally labeling, I was hoping that you could talk a little bit about, allergen labeling and include it with that a little bit, maybe Sesame.

- [Suzanne] Yes, so good point.

Thank you for bringing that up.

So Sesame has recently been adopted as one of our major allergens, and to get back to Martin's question about labeling for allergens, that is one of our more common questions.

So when you have your statements on your product, there's a couple of different ways that you can address allergens and still be in compliance.

So one is with the actual ingredient listing.

So if, for example, you have a product such as, let's go with macadamian nut cookies, right?

So when you're listing out the ingredients, your number one ingredient is probably going to be flour.

In flour, more often than not, we have wheat, which is a major allergen.

So when you're listing that ingredient, you can either list that as wheat flour, which would cover the notification that that is included in the ingredients.

Or you could list flour with parenthesis after it wheat, or you could list just flour and at the end of the ingredient statement have a contained statement where you list all potential allergens in the product.

So for a macadamian nut cookie that may include something such as contains wheat, contains tree nuts, contains egg, milk.

Otherwise you can include those major allergens in the listing of the actual ingredients.

So you don't necessarily have to have that separate statement that says contains, but you do need to ensure that in that ingredient list you are notifying the common name of the allergen so that anybody who may be potentially purchasing your product on the line is aware that that allergen is present.

And as Martin had not mentioned, Sesame is the most recent addition to that list of major allergens.

So you'll wanna ensure that any item like that is also noted on that ingredient list.

- [Martin] I had another question if that's okay?

One of the things I thought was interesting was the fact that when you talked about new product changes, sometimes it's what would your recommendation be for if somebody's making some changes or adding some new products?

Do they always tell the inspector, say it's just a flavor change or it's a like where does that come into play when they should be talking to their inspector?

- [Suzanne] Sure.

So it's difficult to kind of draw a specific line.

We have people who do, we have a lot of home bakers in Pennsylvania and they might be making something such as like assorted pies that are not a problem.

But then maybe around the holidays they decide, I would really like to add a pumpkin pie or a pumpkin roll.

And that's when it becomes a problem because that's when we're seeing products that may require refrigeration.

If you are just doing baked cookies or cupcakes and you're going from vanilla cupcakes to chocolate cupcakes, that's not something that you would need to notify the inspector of about.

But when you're taking on a whole new product, especially if it seems like it's maybe more of a moist baked good, like pumpkin bread, zucchini bread, banana bread, that's when you really wanna notify your inspector.

They're a great resource because they've been through this many times over with all of the firms that they've licensed and inspected.

So they often have a really good set knowledge of what foods require time and temperature control, which ones don't.

Additionally, any time you are adding any kind of acidified food, which more often than not is going to be a product like, a pickled product, then you will certainly want to notify your inspector.

There may be additional requirements for testing or for having a process authority involved.

So for us, the red flags often or moist foods, pickled foods, foods that would contain seafood, raw juice.

So for us, those are usually the big red flags.

But for small changes, going from chocolate chip cookies to shortbread cookies, that's not something that you would necessarily need to let your inspector know about.

- [Martin] Well, I'm asking questions.

Can I ask another question?

So one of the questions that we get a lot of times is a person will call in and their inspector may go and visit them and maybe they don't like the answer they get maybe or maybe they think that and we certainly don't wanna stand in there and never contradict an inspector.

So where can a person go if they have a question or maybe they don't like the ruling that their inspector has provided to them, where can they go or how could they answer, get that question answered?

- [Suzanne] Sure.

If for some reason they feel like maybe the inspector didn't have all the facts or has incorrect information that they're sharing with them, I would always encourage them to reach out either to you guys over at the Penn State Cooperative Extension for clarification, or they could reach out to me directly and you'll see my contact information is up there on the screen and I'm always, all day long taking phone calls, responding to emails with similar questions.

So we welcome people reaching out to our department for clarification whenever needed.

And of course, Penn State Cooperative Extension is a great resource for them as well.

- [Martin] Yeah, one of the things for us, I could say is we never want to contradict an inspector.

We certainly can provide more information about something, more in depth a better understanding of what the inspector was trying to do.

But in cases of where there is a question of whether the inspector's correct or not, we would normally want wanna pass that on to you for that.

- [Suzanne] Yeah, yeah. And feel free.

Not all of our inspectors are trained in the same foods, so we do have some advanced inspectors, so there could be occasions where the inspector just hasn't fully received that training or they're not quite as familiar with that food and need some additional interpretation on it.

But certainly I would welcome people to reach out to me directly if they have any concerns.

- [Martin] All right. Sorry, you were gonna talk. (laughs)

- [Sarah] Yeah, so I did wanna remind folks that you know, if you do have a question, please go ahead and answer that in the chat pod if you are concerned about entering a question because we are recording, I won't read any names and also I can turn the recording off in just a moment too, if that eases anybody's mind.

Suzanne, I did have a question for you.

You mentioned the requirements.

If someone is processing a product that has greater than 50% a dairy product and dairy's kinda my pet area.

And so other than the obvious dairy products, ice cream, fluid, milk cheese, yogurt, et cetera, can you name some of those products that you know might be kind of right on that line just for anybody who is considering their options?

- [Suzanne] I'd say more often than not, typically what I see are cheese spreads or dips.

So sour cream, dips cheese dips, things like that.

I think our department does a pretty good job of filtering requests for milk products to our milk specialists because that is certainly not my area of expertise.

But yeah, I would say more often than not it's cheese dips and spreads that we're seeing.

- [Sarah] Thanks.

- [Suzanne] Yeah, and I would like to also add too, if someone's not comfortable asking a question or if they come up with a question later down the road, feel free to jot down my contact information and reach out to me directly.

- [Sarah] So I am gonna go ahead and stop that recording just in case there is anybody out there that is concerned about that.