Keeping cold hot: 3 things every cold brewer should know about food safety

By William “Bill” Murray, President & CEO, National Coffee Association USA


While not a new format by any means, cold brew has shot up in popularity in recent years and is expected to keep growing. About 16% of coffee drinkers reported having had cold brew in the past week, according to the NCA National Coffee Drinking Trends report – up from only 8% in 2016.  What hasn’t kept pace, however, are clear food safety best practices, guidance, and regulations to help keep this massively popular product – and the customers who demand it – safe. It is crucial to stress that cold brew coffee, like traditionally prepared coffee, is generally safe – but changing times and evolving brew methods call for food safety vigilance – despite coffee’s long, safe track record.

That’s why, with help from our team of scientists on the NCA Science Leadership Council (and support from our cold brew partner BUNN), NCA has created the all-new Cold Brew Safety Guide for Retailers along with several other new resources to help coffee retailers safely brew, store, and serve cold brew – one of the hottest drinks in coffee today.

Here are three key things every cold brew retailer should know to help keep their cold brew coffee food-safe:

1. The “danger zone” for cold brew where bacteria can grow is 41-140˚F.

Brew, store, and serve your cold brew at a temperature of 40˚ F or below to minimize the risk of pathogens like botulism that could cause foodborne illness. Above 140˚F, most toxin-producing bacteria are killed. However, while cold brew doesn’t technically have to be served cold, it may lose some of the smooth taste and flavor your customers have come to expect from cold brew if heated above this temperature.

2. Retail dispensed cold brew (i.e., made on-premises in a coffee shop) and RTD cold brew are not created equal – and each requires special safety considerations.

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RTD packaged cold brew is cold brew that is manufactured and bottled under aseptic conditions in a manufacturing facility following FDA’s low-acid food regulations (21 CFR Part 113), whereas dispensed cold brew is often prepared and served on-site at a retail location and is regulated by a local health inspector following FDA’s Food Code.

Dispensed cold brew is generally prepared at 40-70˚F overnight at a retail location using roasted coffee and filtered water and can be infused with nitrogen to make nitro cold brew. The cold brew can be stored in airtight or covered (non-airtight) containers.

Health inspectors examining a retail dispensed cold brew operation may require a HACCP Plan – see more on HACCP Plans below.

NCA’s 2018 Cold Brew Toolkit for Industry dives into RTD cold brew safety considerations, while dispensed retail cold brew (and its potential food safety risks) are covered extensively in the just-released NCA Cold Brew Safety Guide for Retailers (2022). Both are available here

 3. You might need a HACCP Plan.

Every retail cold brew operation should determine whether a Hazard Analysis and Critical Control Point (HACCP) Plan is necessary. This seven-step framework is critical in reducing hazards in food to acceptable levels, and consists of:

  • Hazard analysis.
  • Critical Control Point (CCP) identification.
  • Establishing critical limits.
  • Establishing monitoring procedures.
  • Setting corrective actions.
  • Setting verification procedures.
  • Establishing record-keeping and documentation.

A HACCP Plan is generally not required in retail locations unless the cold brew is brewed, held, and served above 41˚F, or if it is held in a container with an airtight lid for over 48 hours.  NCA offers a model HACCP Plan that our Members can refer to when developing food safety protocols for their own retail cold brew business.

You can learn more about NCA’s Cold Brew safety resources in our NCA Cold Brew Toolkit, which includes our new Cold Brew Safety Guide for Retailers, our 2018 Toolkit for Industry, a model Hazard Analysis and Critical Control Point (HACCP) Plan, answers to frequently asked questions about cold brew and a compliance checklist to ensure you’re ready when the health inspector comes knocking.

NCA: We serve coffee (and want the cold brew coffee YOU serve to continue its long record of food safety.)

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