8 replies to this topic

[JesseG]

Hi,

Can anyone give me their opinion on this?

Work in a low risk baking environment.

Our product is sent out frozen to be further baked etc. packaged in store.

Our dry ingredient allergens on site are soy flour, milk powder and tree nuts.

We were given a CAR in an for having the same scoops for soy flour and milk powder. Product where these two are not added intentionally, we still label "may contain traces of soy, milk".

Can we not use the same scoop for both ingredients?

Thanks,

Paula

[Blossom]

Well IMO , If all your product contain Soy, milk and tree nuts they should not be considered as allergens.   

[JesseG]

^{Hi - they don't all contain these three.  For example, if a product has milk powder but no soy added intentionally or from other ingredients, we still state (may contain soy) because of the scoops.}

Edited by paulajgr, 31 October 2013 - 10:25 PM.

[Madam A. D-tor]

You should do your very best to prevent cross contamination with allergens.

Just depending on the "may contain'-statement is not correct.

 

To minimise the cross contamination risk e.g. by using dedicated scopes is documented in the requirements of the standard, is legal requirement and should follow from your risk assessment.

 

5.2 (fundamental) The company shall have a developed system for the management of allergenic materials which minimises the risk of allergen contamination of products and meets legal requirements for labelling.

 

5.2.3: A documented risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross-contamination is avoided. This shall include:
- consideration of the physical state of the allergenic material, i.e. powder, liquid, particulate
- identification of potential points of cross-contamination through the process flow
- assessment of the risk of allergen cross-contamination at each process step
- identification of suitable controls to reduce or eliminate the risk of cross-contamination.

 

5.2.4: Documented procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination into products not containing the allergen. This shall include as appropriate:
-[...]

-  use of identified, dedicated equipment and utensils for processing
- [...]

Edited by Madam A. D-tor, 01 November 2013 - 12:01 PM.

[Charles.C]

Dear paula,

 

Basically it sounds like, as elaborated in previous post, the auditor took exception to yr usage of labelling as an "evasive" control measure. Not so rare of course and possibly within local regulatory requirements (?).  BRC clearly have a more aggressive viewpoint.

 

Rgds / Charles.C

[YongYM]

To Paula:

 

Just to share with you that we use different scoops to take sample of incoming raw materials upon receiving and different (coloured) scoops to prepare (weigh) the ingredients before mixing. I know it is very troublesome but we should try to do our best (to minimize cross-contamination) even though our finished products are also labelled with "may contain traces of .......".

 

 

Yong

[moskito]

You should do your very best to prevent cross contamination with allergens.

Just depending on the "may contain'-statement is not correct.

 

To minimise the cross contamination risk e.g. by using dedicated scopes is documented in the requirements of the standard, is legal requirement and should follow from your risk assessment.

 

5.2 (fundamental) The company shall have a developed system for the management of allergenic materials which minimises the risk of allergen contamination of products and meets legal requirements for labelling.

 

5.2.3: A documented risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross-contamination is avoided. This shall include:
- consideration of the physical state of the allergenic material, i.e. powder, liquid, particulate
- identification of potential points of cross-contamination through the process flow
- assessment of the risk of allergen cross-contamination at each process step
- identification of suitable controls to reduce or eliminate the risk of cross-contamination.

 

5.2.4: Documented procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination into products not containing the allergen. This shall include as appropriate:
-[...]

-  use of identified, dedicated equipment and utensils for processing
- [...]

I agree. Just to write "may contain...." and to avoid any measure to minimize the risk is for my understanding not, what GMP means. And our customers will accept a "may contain..." only, in we demonstrate what we have done to reduce the risk. BRC adresses the point and our authorities will come for inspection of GMP if they will detect "more than a trace" in the product. What is a trace? No definition - only a personal view of the inspector.

 

Rgds

moskito

[Mr. Incognito]

I agree with Moskito.

If you are using the same scoop the presence of that allergenic protein is still going to be on the scoop... and as such you should change your label from “may contain” to “we intentionally put it in there.”

Using one scoop for a number of allergens is not only a bad practice but could get someone killed.

The best practice would be to have different color, or differently labeled, scoops for each allergen.

[Simon]

Whenever I consider whether a control measure is reasonable or not, I weigh in the one hand the risk and in the other the time, effort and cost of putting in the control measure to mitigate that risk.  In this case it is quite easy and low cost to get dedicated scoops of a different colour.