Receiving Frozen Raw Materials - Allergen
Charles,
Thank you for your response. I hope I can simplify a little more. I apologize for the confusion.
We received a tote of Frozen Broccoli from our Supplier. Tote was fully identified except it had an additional tag saying allergen. The product (Tote) was placed "On Hold" ;however, with this tote, there was 15 more totes that came in the same trailer and all their Identification seemed to be an order. The vendor is not telling us what kind of Allergen was in the tote prior to the Broccoli and if the other 15 totes were used to ship Allegenenic Product.
Could this tote be potentially cross contamnated?
Is testing the product a prudent step to make sure the broccoli is not cross contminated with an allergen?
What About the rest of the cargo or load? Should we test the rest of the load that came with the tote as well to make sure the rest of the load is not cross contaminated?
If the testing proves negative, Will it be prudent to use the product? or Send it back to the Supplier and let them prove to us the product is safe.
If you can share any thoughts, it will be greatly appreciated.
To all,
Scenario -
We discovered a Tote of Broccoli (900 to 1000 lb cardboard container) that it had a label saying Allergen. It came from an approved supplier and the label is not ours. The tote is isolated and "On-Hold Status". The tote has a liner inside and the product is inside the liner. (No direct contact with the cardboard.)
Question:
Is this particular tote considered cross-contaminated?
Is the load under that particular Lot # considered cross contaminated? (This tote was part of the load)
Do we have the grounds to send to tote and may be the full load back to the supplier for not having a good Allergen Control Program?
Any comments or suggestions would be greatly appretiated in how to handle a situation like this.
Dear kellio,
I don’t entirely understand the situation. A little more detail would help.
I presume you referring to yr control of a lot of frozen incoming raw material, ie broccoli? Import or ?
This was one tote in a lot of 10 totes ? 1000 totes ?
You mean you found an anonymous piece of paper stuck on the outside of the box with the word allergen written on it ? no other text at all ? No indication of origin ? No other labels on the box?
The other totes have typical product labels attached ?
Do you mean you think someone has inspected the lot, selected this tote, analysed the contents and believes the product contains an allergen ?
Why not ask the supplier what it means ?
Rgds / Charles.C
Charles,
Thank you for your response. I hope I can simplify a little more. I apologize for the confusion.
We received a tote of Frozen Broccoli from our Supplier. Tote was fully identified except it had an additional tag saying allergen. The product (Tote) was placed "On Hold" ;however, with this tote, there was 15 more totes that came in the same trailer and all their Identification seemed to be an order. The vendor is not telling us what kind of Allergen was in the tote prior to the Broccoli and if the other 15 totes were used to ship Allegenenic Product.
Could this tote be potentially cross contamnated?
Is testing the product a prudent step to make sure the broccoli is not cross contminated with an allergen?
What About the rest of the cargo or load? Should we test the rest of the load that came with the tote as well to make sure the rest of the load is not cross contaminated?
If the testing proves negative, Will it be prudent to use the product? or Send it back to the Supplier and let them prove to us the product is safe.
If you can share any thoughts, it will be greatly appreciated.
Charles,
Thank you for your response. I hope I can simplify a little more. I apologize for the confusion.
We received a tote of Frozen Broccoli from our Supplier. Tote was fully identified except it had an additional tag saying allergen. The product (Tote) was placed "On Hold" ;however, with this tote, there was 15 more totes that came in the same trailer and all their Identification seemed to be an order. The vendor is not telling us what kind of Allergen was in the tote prior to the Broccoli and if the other 15 totes were used to ship Allegenenic Product.
Could this tote be potentially cross contamnated?
Is testing the product a prudent step to make sure the broccoli is not cross contminated with an allergen?
What About the rest of the cargo or load? Should we test the rest of the load that came with the tote as well to make sure the rest of the load is not cross contaminated?
If the testing proves negative, Will it be prudent to use the product? or Send it back to the Supplier and let them prove to us the product is safe.
If you can share any thoughts, it will be greatly appreciated.
Dear Kellio,
Thks for the clarification.
Is it a common occurrence for these totes to be used for “anything” ? and labeled with comments like “allergen”? Offhand, it could mean literally anything to me.
Must admit I have very limited experience with Broccoli, or fresh vegetables in general.
I deduce that “allergen” is a typical hazard in this raw material (http://www.pollenlib...GENUS/Brassica/ )
But I daresay not required to be (legislatorily) involved with product labeling in yr locality ?
Are other cross-contamination vegetable (?) allergens (or above one) a known problem in yr business ?
How about the contractual raw material product specification, if any ? Yr customer specification ?
My response would be related to knowledge - experience with this product / supplier / customer / business etc.
Eg if I had never worked with this supplier before, had sufficient supply of equally acceptable quality material from other suppliers with no subsequent problems and at an equivalent cost; a lack of willingness to communicate as you mention would simply prompt a lot rejection. And particularly if you have already experienced specific problems over “allergens”.
Hope this is slightly useful. Other vegetable users here may have more direct input.
Rgds / Charles.C
In addition to Charles' comments, I don't know how you would go about testing for 'an allergen'? You would presumably have to test for every allergen listed in the relevant labelling regs, which could prove expensive! And even then, at what level would you regard the allergen to be significant?
I wouldn't mess about with this, just reject and let the supplier explain their strange behaviour!
Barrie
If I were in your situation, the least I would insist on is a CoA from the supplier stating that the product was free from (named) allergens. Although this does not absolve you from your responsibilities under due diligence
Alternatively, you could raise a non-conformance and reject the product. Take photos of the tote, record batch numbers etc (in case they try to redeliver at a later date) and just get it off your site if our not comfortable with their response. My next move would to be to carry out a full diligence audit of them as a supplier and mark them down as high risk.
Caz x
Unless the supplier is forthcoming and tells you what was previoulsy in the tote, I'd pass on that one for sure. Also, insist on knowing what was in all the other totes as well. Maybe ask for a copy of their tote cleaning procedure as well.
Thank you for your responses.
In the frozen vegetable industry, the totes are "card board big boxes" with plastic liner inserted inside designed to hold 900 lbs to 1200 lbs and they are recycled from supplier to supplier for the most part until it is unsable. New Totes are a great expense for replacement. The product is processed and frozen by the time we get it from the supplier. We currently test for the basic 8 Allergens because some of our ingredient we put in our vegetables are allergenic, we test for the basic 8. The load I mentioned it was all broccoli.
If the tote was exposed to an allergen before it was used for Broccoli, it could be a potential problem.
Your comments gave me an idea where we need to improve our checks when receiving frozen raw material and hold the supplier accountable.
Thank you, this is good stuff.