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Allergen Risk Assessment

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Techy

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Posted 01 March 2009 - 01:49 AM

Hi All

Our company is under pressure to remove all ' may contain' labelling which is used for category 1 allergens: peanuts, nuts and sesame. I can understand that our customer wants to help allergen sufferers as they feel the food industry is using it as a ' ass covering' excercise.

We do not use 'may contain' labelling for any of the allergens that we handle on site as we do not handle peanuts, nuts or sesame so the risk is only thorough ingredients supplied to us.

We have been asked to go back to our suppliers and challenge them on thier own controls and if they can't control cross contamination in ther factories then we should audit them and if are not confident about their controls then we shoudn't be using them. We have started this excerise and have come across several companies who do not want to remove the ' may contain' claims for peanuts, nuts and sesame as they feel they have no control of their product prior to it arriving to them. One example was for seasoning.

So far I have contacted 3 suppliers and they are all alligned. What do i do ? Take the risk upon my own head? How can I risk assess the probability that a peanut may accidently come and contaminate the seasoning during the growing or harvesting and contaminate our product?

Where do I stand legally if I remove the ' may contain'

Help all ideas and thoughts welcomed



Charles.C

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Posted 01 March 2009 - 05:37 AM

Dear Techy,

Tks for this question which I’m sure must hv generated considerable global discussion already.

as they feel the food industry is using it as a ' ass covering' excercise.


We have been asked to go back to our suppliers and challenge them on thier own controls and if they can't control cross contamination in ther factories then we should audit them and if are not confident about their controls then we shoudn't be using them.


I’m sure both these statements would hv a decisive majority consumer agreement. Frankly, the second one involving auditing is also effectively a manufacturing axiom IMO.

Not myself in UK but I expect the legal situation is strongly influenced by yr “due diligence” rules. More direct operational info is hopefully available in the links given here –

http://www.food.gov....maycontainguide
(seen already probably ?)

You might be interested to know that, from memory, omission of allergen warning on labels where subsequent investigation proves the existence (or perhaps even the “possibility of occurrence” ) is the most frequent item within the reported removal / recall incidents on this forum. No doubt linked to the potential for severe reactions in some allergenic situations.

The usual first step in a risk assessment is to ensure the existence of appropriate, mutually accepted, product / raw material specifications. The degree of necessary parallel verification / validation of such content is more complex to specify and often depends on the specific case but is certainly non-zero, eg audits etc as you mention. There are several threads on expanded methodologies for risk assessment in this forum.

I’m interested to see comments from more directly involved posters.

Rgds / Charles.C

Kind Regards,

 

Charles.C


Madam A. D-tor

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Posted 01 March 2009 - 10:22 AM

Hi Techy,

Are you saying, that you are labelling "may contain", because your suppliers use ingredients (seasonings) for the products supplied to you, which they are not sure it may contain some unintentionally allergen contamination?

Can you validate that this contamination will never exceed the limits in your products?

The contamination in the seasoning will be small, this seasoning goes in the products supplied to you. These ingredients are also a percentage of your finished products. What will be the value in your product, if this seaasoning was indeed contaminated?

To me this seems very strange, but certainly it has to do with your due dilligence policies, as also mentioned by Charles.


Kind Regards,

Madam A. D-tor



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