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Controlling Non-Food Allergenic Material

Allergens Chemicals non-food Compliance

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#1 AGomez

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Posted 05 March 2015 - 08:41 PM

Hi everyone!

 

I've never introduced myself but I am new to the site. I am the Regulatory Compliance Officer for a small co-packer of dried, powdered, granulated, and pieced facility that includes foods and non-foods (mainly soaps). All we do is package and does not include blending, mixing, cooking, or temperature controlled storage and our facility is physically broken into two parts (foods/non-foods). We package foods that have allergens so are very aware of the hazards and controls needed to prevent cross-contamination but we recently got a customer whose soaps have milk powder. Is there a regulation or law (USA) that states the machine/equipment/room must be cleaned and sanitized between those non-food products?


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#2 fgjuadi

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Posted 05 March 2015 - 08:48 PM

Well, the law says that food can't be contaminated with an allergen if it isn't declared on the label.  

 

You can test your line for casein after you run the soap.  If the surfaces of the line have casein after you run the soap, and they touch food or might transfer to food, then you have to clean and sanitize the line. 

If there is no milk allergen protein on the food contact surfaces or the line, there's no need to clean it.  

If there is allergen protein on the line and you need to clean, after you clean, test again - if the protein is still present, it isn't clean enough.

 

I use neogen, but there are other rapid detection ELISA kits out there.  It costs roughly $10 / test and doesn't need any extra equipment.  Plus it only takes 5-6 minutes. 

 

Should be pretty easy to clean if it's all soaped up though!


Edited by magenta_majors, 05 March 2015 - 08:49 PM.

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#3 AGomez

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Posted 05 March 2015 - 09:00 PM

Our foods and non-foods never comingle. Our facility is physically split into two separate production facilities although there is a personnel and forklift door adjoining them. Also, we have dedicated food and non-food equipment.


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#4 fgjuadi

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Posted 05 March 2015 - 09:30 PM

Ah, you're asking if the non food products (cosmetics or FDA regulated?) you're running next need allergen declaration or clean out

 

Well - from the FDA FAQ

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FDA does not have the same legal authority to require allergen labeling for cosmetics as for food.

 

Anything outside of  cosmetics / drugs usually falls under CPSC, but I'm not familiar with any allergen declaration laws.  Of course, that doesn't mean they don't exist.

 

The EU has fragrance declaration laws


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#5 Charles.C

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Posted 06 March 2015 - 10:30 AM

Dear AGomez,

 

I'm slightly confused regarding yr precise query so i have noted my interpretation of yr OP. maybe it's just me that's confused. :smile:

 

i deduce that the food packaging section can be ignored within the context of yr question since zero possible interaction with non-food section. OK.

I deduce yr query only relates to products run in the Non-food section.

 

Is yr query then some /all of  -

 

(a) whether soap (eg product A) which contains a dairy ingredient (milk)  must declare the presence of dairy allergens on the label ?

(b) whether other non-food items processed after A require the shared  line/environment to be cleaned/sanitised and validated free of dairy allergen. Or perhaps appropriately labelled, eg "may contain dairy allergen" ?

© whether, as per MM's post, any regulations exist regarding potential cross-contamination of "other (??)  kinds" between non-food products using shared-line, etc and related, required, measures of avoidance.

 

Personally i have no idea to (a,b,c) but for USA the regulatory answers are (maybe partly)  within here -

http://www.fda.gov/C...s/ucm074162.htm

 

I could not find any mention of the word "allergen" in above link. As in foods, Adulteration appears a popular US strategy.

 

Have attached a recent UK based, allergen oriented, survey of some eclectic non-foods (including cosmetics, personal care [soaps et al], medicines and condoms). The text implied (to me) that, in the present context, regulations/labelling requirements are mostly rare, often non-existent.

 

Attached File  Non-food allergen problems.pdf   299.12KB   23 downloads

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C






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