Allergen Verification Cross Contamination Crustaceans and Molluscs

I know there is a thread for this but I need a quick answer.
We process Crustaceans and Molluscs, both are allergens. I have to consider the possibility of cross contamination .
If I can show with risk assessment that there is a very low risk of cross contamination between from Molluscs to crab, do I absolutely HAVE to verify it using testing? There is no testing available for molluscan allergen to date ( I have spoken to Neogen).

If I can't prove it, do I have to take the labelling route, even though I can show that the risk is minimal to begin with...

The molluscs and crustaceans can be delivered in the same Truck and may be stored in the same chill before processing , once in process there are completely different lines.
Crustaceans go through 4 stages where washing occurs ( Sleeper tank, Cooking, Chilling, and a high power wash) so the amount of molluscan allergen should be undetectable.

Please Help I am going round and round in circles.

Can anyone help trubertq out with this query?

Thanks,
Simon

While I'm unable to give you the definitive answer you are looking for, I am having a similar crisis with soya at the moment. The main problem I see is the lack of lower levels for all allergens (with the exception of Sulphur Dioxide) in the European legislation. Based on my experience and neurotic sweaty panic attacks, I would always say go for the labelling option if there is any doubt whatsoever. I understand your frustration, especially when the risk is so low and it can cost to change retail packs in particular, but if in doubt and all that... Perhaps some auditors out there could be more helpful, but with my backround, I would almost see a cross contamination issue from them even sharing the same sea!

Dear trubertq,

Unfortunately you didn't mention regarding verification to whom.? Internal only ? Regardless "local" (destination) regs may still apply ?.

From a parallel thread below, it is clear that Europe is not the only area having difficulties, maybe the USA can offer you a numerical way out (I didn't check the other crustacean thread for anywhere else?)

http://www.ifsqn.com...dpost__p__55485

Rgds / Charles.C

Germany's R-Biopharm offers an LF and ELISA kit for crustaceans, as does Romer Labs (ELISA only). Several PCR tests in the marketplace for molluscs, including one by R-Biopharm. Suggest you contact them for assistance.

I know there is a thread for this but I need a quick answer.
We process Crustaceans and Molluscs, both are allergens. I have to consider the possibility of cross contamination .
If I can show with risk assessment that there is a very low risk of cross contamination between from Molluscs to crab, do I absolutely HAVE to verify it using testing? There is no testing available for molluscan allergen to date ( I have spoken to Neogen).

If I can't prove it, do I have to take the labelling route, even though I can show that the risk is minimal to begin with...

The molluscs and crustaceans can be delivered in the same Truck and may be stored in the same chill before processing , once in process there are completely different lines.
Crustaceans go through 4 stages where washing occurs ( Sleeper tank, Cooking, Chilling, and a high power wash) so the amount of molluscan allergen should be undetectable.

Please Help I am going round and round in circles.