11 replies to this topic

[ronragus]

HI, I am new to the seafood processing industry and is trying to wrap my head around when kind of allergen control is necessary if a facility processes both fish and crustaceans. I looked at major allergens listed under US and Canada and can see that Crustaceans and fish are usually in separate categories- what I wasn't sure is if the industry typically keep crustacean processing separate from fish processing (and vise versa) to mitigate allergen cross-contamination?

 

I am assuming ingredient storage/final product storage between these 2 different types has to be secregated, as well as there need to be an adequate allergen cleanout before changeovers if a facility processes crustaceans and fish in the same processing line? I don't think having a precautionary statement to mention may-contain-fish/crustacean will provide an exemption for not having a system to control the 2 groups of allergens separately....?

 

Any pointers/thoughts from experts from the seafood industry is greatly appreciated!

[Charles.C]

Hi ronragus,

I assume the finished product (which is ?) is intended to be commercialized in Canada.

What are the Regulatory Canadian labeling requirements as will be applied related to the allergens you mention for the intended finished products ?

[Charles.C]

addendum

 

Note that from a Consumer's POV, the typical generic hazard in the finished product  is "Undeclared allergen".

 

I attach what appears to be a fairly detailed, seafood-specific (2013) summary of the USA situation -

 

 Food allergen labelling,USA -haccp control for seafood industry,2013.pdf   1.31MB   56 downloads

 

As you noted in OP, "fish" and "crustaceans" are FALCPA listed hence involving Regulatory actions.

afaik (see the attachment), the FDA process viewpoint is that for FALCPA listed allergens, significant risks for allergenic cross-contamination as determined by a hazard analysis for your process must be minimised, eg by GMP. Such expectations are unchanged by the use of "precautionary labelling".

 

From a labeling POV, and based on a quick IT look, Canada appears to allergen classify fish and crustaceans within "Seafood" (???), ie not differentiated. I haven't further checked but if correct this could presumably result in a different hazard analysis to the US scenario.

 

http://www.inspectio...6/1332442980290

http://www.hc-sc.gc....n/index-eng.php

[CMHeywood]

Crustacean have hard shells.  Fish don't.  It may be just a matter or adequately identifying the differences.

 

Keeping them separate may be to avoid cross contamination of allergens, but I don't know if someone could be allergic to crustaceans and not fish.

 

However, there is an issue with Kosher foods.  Crustaceans are not allowed in a strict kosher diet.

 

it might be due to bacteria and viruses that occur in one species more frequently but can transfer to another species that rarely is contaminated with the same bacteria or virus.

[GMO]

The simple answer is yes.  People who have allergies to fish like cod for example, may not have a prawn allergy.  Even within a category you can have someone who has an allergy to crab for example but not to brown shrimp.  That said, controls around allergens in most factories aren't this good but I'm going to try and convince you that they should be.

 

I have worked in the food industry for quite a few years and it wasn't until my son was diagnosed with a specific nut allergy that I appreciated that controls are needed to improve.  My son has an allergy to one tree nut and none of the others.  His specialist has recommended that he continues to eat other tree nuts and peanuts to avoid developing an allergy to these nuts.  So the advice at least from some specialists used to be "avoid all nuts" if one allergy was detected and now it's the complete opposite.  This is the same in some other allergens too depending on the severity in the patient but there hasn't been the joined up thinking to link advice from doctors to what happens in the factory.

 

So what you should assume is that someone eating a product labelled with crab could well be fine with crab but allergic to prawns and not recognise that as a potential risk.

 

And this is where people look in the klipspringer catalogue and work out how many colours they have and start to cry.

 

But dry your tears!  There is a solution and the solution (if you excuse the pun) is effective cleaning.  It is rare if not unheard of for a factory to have a dedicated sauce kettle or oven to a single allergen.  Why is it then when weighing out ingredients we suddenly start to think we need 101 different colour scoops?  Then if you factor in religious restrictions and species as well you're going to be struggling.  I would do the following.

 

Plan allergen runs for the end of the day if you can.

Weigh out using or into disposable containers if possible.

Use good air extraction for powdered allergens, possibly segregating the weigh area for these.

Validate your cleaning processes using ELISA if you can.

Verify your cleaning processes; this may be acceptable to be visual in some cases but it's likely to mean rapid allergen test kits in yours.

 

My last point is don't be unduly scared.  I once went on a training course with the brilliant RSSL (who now no longer run the fab "allergens in a nutshell" course they used to.)  They said something which has stuck with me ever since.  In all of their research where people had died from allergens, it had always been the allergen was part of the recipe but not declared or the person who had the allergy didn't check the ingredients.  It hadn't happened where someone died from cross contamination.  Not saying it couldn't but it does make you get a little more pragmatic and also it makes you realise the truth and that is the most likely place in your factory where you will have a massive incident resulting in a high dose of undeclared allergen?  Your labelling / packing department.  Getting the wrong packaging (and so the wrong ingredients declaration) is the biggest issue you need to face.

[Charles.C]

Hi GMO,

I appreciate all yr points however, based on the legal labelling requirements, the operational conclusion for Canada may be No. See post3.

I was unable to locate a reference to the current processing situation.

[Scampi]

an excerpt from the health canada link as posted above, it explains why Canada has lumped them together:

Frequently asked questions about seafood allergies What is the difference between crustaceans and shellfish?

Crustaceans are aquatic animals that have jointed legs, a hard shell and no backbone, such as crab, crayfish, lobster, prawns and shrimp. Shellfish (also known as molluscs) have a hinged two-part shell and include clams, mussels, oysters and scallops, and various types of octopus, snails and squid.

How can I avoid a fish, crustacean or shellfish-related reaction if I'm allergic to these foods?

Avoid all food and products that contain fish, crustacean or shellfish and their derivatives. These include any product whose label carries a precautionary statement warning that the product "may contain" or "may contain traces of " fish, crustaceans or shellfish. Fish, crustacean and shellfish will be listed on the label of prepackaged foods using their common names (e.g., tuna, salmon, lobster, crab, clam, oyster, etc.)

Who is affected by seafood allergies?

Crustacean and shellfish allergies predominantly affect adults and are rare among young children. In North America, fish allergies are more predominant in adults, while in countries where fish is a dietary staple, fish allergies are common among both adults and children. Allergies to fish, crustaceans and shellfish are usually lifelong conditions.

[Scampi]

So the way Canadian regulations work is, you MAY add a precautionary statement, but that is not to replace good GMP's and sanitation program. We process a bird species that is not the norm, and as such they produce eggs much younger than commercial chickens or turkeys, our finished product MUST be labelled with a "may contain egg" statement as we cannot change the physiology of the bird.

 

Ronragus, are you following FSEP as well, or just a HACCP plan? I know meat and poultry must follow FSEP, but I'm not sure about fish/seafood plants

[Charles.C]

Hi scampi,

I'm not quite sure whether the previous posts were a yes, no, or a maybe.

I found the info. In the two links I previously posted a bit confusing. I deduced from the first one that for Canadian labeling regs any single "kind" of the 3 mentioned types of seafood or more than one kind should result in the same labeling statement from an allergen POV, namely "seafood". This would not be a "precautionary labeling" as I understand the term. It is unclear to me what the second link requires from a labeling POV since IMO the text is ambiguous. Do all labels use the "may" format ? This would then be total precautionary labeling and thereby require segregation as you mentioned. Need to see an example.

[GMO]

Hi GMO,

I appreciate all yr points however, based on the legal labelling requirements, the operational conclusion for Canada may be No. See post3.

I was unable to locate a reference to the current processing situation.

 

Thanks, I get what you mean but likewise in the UK it would be perfectly legal not to segregate tree nuts but it doesn't make it best practice or advisable.  As someone who lives with a child who has a food allergy, it is not just possible but sensible to segregate. 

[Scampi]

To clarify, for the seafood, it would be up to the operator as to whether or not to add a may contain statement; let's assume today i am processing cod int he morning and crab legs in the afternoon, I do not NEED to do a full clean and sanitise (by Canadian standards for allergens) but I may choose to add a may contain fish(cod) statement to the label under the crab legs list of ingredients.

 

For me, because I am poultry and have to follow the FSEP manual as well as the poultry procedures, and FSEP is the portion that has forced us into adding a precautionary statement for egg

 

NOTE: not all Canadian commodities are forced to use HACCP at this time....this WILL change next year. ALL meat/poultry eggs and dairy are mandated to follow HACCP, the corresponding manual of procedures and the FSEP manual

[Charles.C]

Hi ronragus,

 

It's an interesting thread.

 

Yr basic questions were  – (i) is fish/crustacean/shellfish storage segregation required in Canada ?, (ii) is changeover process cleaning of equipment required where single line in use for 2 or more of 3 entities in (i) ?

 

A few comments -

 

(a) I am unclear as to Canadian  Jurisdictional (ie Federal/State) scenario for Seafood Process industry. (cf USA where USFDA, afaik, totally Rules Seafood Processing).

(b) I am unclear as to whether any relevant Canadian Regulatory rules consider the occurrence of fish/crustaceans/shellfish) as ONE allergen (ie Seafood [fish, crustacean or shellfish]) from a Processing POV. This is so far unresolved (to me) from viewing CFIA website although links in Post3 seem to support this (Labelling) opinion.

© I am unclear with respect to Canadian Labelling whether “blanket”  Precautionary Style labelling is accepted. Scampi’s previous post suggests Yes  and similarly this (cynical?) file (2016) –

 May Contain Traces of Allergen Precautionary Statements and Allergen Management.pdf   1.49MB   63 downloads

 

Yr  allergen queries have occurred in different ways many times on this Forum although rarely (if ever) relating to Canadian Seafood Industry. A number of “analogous” threads (eg multi-“allergens” within "allergen X” ) are here -

 

http://www.ifsqn.com...ain-processing/

 

http://www.ifsqn.com...in-the-factory/

 

http://www.ifsqn.com...ilemmaquestion/

 

http://www.ifsqn.com...eling-concerns/

 

The typical (Process) conclusion to the above  threads is “non-definite”.

 

If  “Seafood” is designated as the allergen, segregation and changeover cleaning are IMO unlikely to be a Regulatory demand where fish and shellfish are stored together and processed on the same line. Recommendations for seg./cleaning may of course exist, eg this quote from link in Post 3 -  

 

The CFIA enforces Canada's labelling laws and works with associations, distributors, food manufacturers and importers to ensure complete and appropriate labelling of all foods. The CFIA recommends that food companies establish effective allergen controls to prevent the occurrence of undeclared allergens and cross-contamination. The CFIA has developed guidelines and tools to aid them in developing these controls.

 

Some input from a Canadian seafood processor of appropriate products would be nice.

 

PS - Just as a contrast to above manouevres, here is a quite neat Canadian example of a more purist / haccp-friendly Allergen Control Plan -

 ALLERGENS CONTROL.doc   46KB   90 downloads