5 replies to this topic

[Gilles]

Hello all,

 

I need your help regarding allergen control. 

Here we process and pack seed, kernel and cereal products, the products are always dry and solid. No water is used during the proces.

Now because of the products we have the following allergens:

- Gluten

- Soy

- Sesame seeds

 

when we change product, the whole line is cleaned with air and some older product (the same as we are going to proces) goes through the line to remove the previous product.

 

Now the problem, on all product we declare that there is a cross contamination risk for all 3 allergens, and customers do not like it (and nether do I)

In his mind the contamination could start at the field, next to the field of seed there are wheat fields (for example) so during the harvest its possible that there is cross contamination.

 

Because the product is dry and solid I can swap the line everywhere and I will not find traces of allergens but because there is a chance that a sesameseed is left on the line my boss does not want to take any risk.

 

How would you handle this? Is he right or...

 

thanks

[Jcchaser]

After the wash down you can test for allergen.  We make ground beef patties with Soy in them and after our wash down we test the equipment to see if their is any trace of soy on the equipment.  

[Gilles]

we already do the swaps after dry cleaning and no traces of the product is found.

 

The problem is that there is always a posibility that a seed is stuck somewhere in the device that may come loose and be mixed in an other product. This is why my boss wants to keep declaring these allergens.

 

PS.

We can not clean with water due to the nature of our product

[Charles.C]

Hi Dongilles,

 

One ethical argument in support of yr boss is that the lethality of allergenic components is unpredictable, possibly fatal, and since you are unable to guarantee that there will be zero contamination it is a justifiable approach to warn potentially sensitive consumers thereby giving them the choice to purchase or not.

 

Another non-ethical argument is the more obvious one related to insurance "risk".

 

Advisory labelling is a bit of a minefield. IIRC, USFDA require you to be able to demonstrate that the risk of cross-contamination has been process-minimised but also allow the labelling to contain a "blanket" warning.

[cerving]

when we change product, the whole line is cleaned with air and some older product (the same as we are going to proces) goes through the line to remove the previous product.

 

What if the older product is already contaminated? 

 

I'm not familiar with dry product (we do frozen fruits/veg), but we do a wash down with chemical, rinse, air dry (via compressed air) then sanitize and air dry (again, via compressed air).  Our air lines are tested regularly (coliform, e.coli and APC).  We then do allergen testing on various areas of our lines. 

 

As long as your lines are fully dry after cleaning, I don't see that you would have an issue running dry product.

[mgourley]

"May contain" statements or "Produced in a facility that also" statements are not an excuse to NOT clean between allergens.

They are consumer warnings. And thus SHOULD be part of your labeling statements, if you CANNOT guarantee the absence of the particular allergen.

For several allergens, there are no "in house" tests that can verify the presence (or not) of particular allergens in a timely manner.

Include the advisory language on your packaging, but still clean and at least inspect for visual residue (and document) between changeovers.

 

Marshall