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Labeling and Allergen


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Ayman Zaki

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Posted 25 March 2014 - 11:44 PM

Hello everybody, I moved to a facility that cleans grains and cereals in terms of removing the physical hazards (Located in the US). All the finished products are for industrial sales. They are in bulks/ large bags. We run Wheat on only one line, however, there are other non-allergen products could be cleaned on the same line (of course after the cleaning and verification checklist). The argument is that one possession claims that we don't need to call "This facility has .... products" because this is voluntary and not required for industrial sales. Other possession is that we need to call this statement out on our labels. FDA seems to identify this only for retails. What are your ideas? Are there any supporting regulations? Do European regulations have specific regulations for this case? Thank you!! Ayman



Bean Queen

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Posted 26 March 2014 - 09:48 PM

Most customers will inquire as to whether you have allergens in your facility and does a risk assessment.  They will ask whether or not there is a potential for cross-containation. A caution statment is not required unless your cleaning and verification data indicates possible carry over even after you have done your due diligence to prevent cross contamination. Truth in labeling is what decides the statement.



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Charles.C

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Posted 26 March 2014 - 10:49 PM

Most customers will inquire as to whether you have allergens in your facility and does a risk assessment.  They will ask whether or not there is a potential for cross-contamination. A caution statement is not required unless your cleaning and verification data indicates possible carry over even after you have done your due diligence to prevent cross contamination. Truth in labeling is what decides the statement.

 

Dear Bean Queen,

 

As per the OP, legislation may also be an issue in addition to "Truth". If it exists (in this case). Any idea ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


Ayman Zaki

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Posted 27 March 2014 - 01:12 AM

Bean Queen, Thank you for comment. Yes, all customers ask about the allergen program. The issue is just a challenge between two sides on the regulatory knowledge. Thanks, Ayman



Intlft96

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Posted 27 March 2014 - 01:00 PM

Dear Bean Queen,

As a member of the manufacturing community, those of us in FS and quality systems function would love it if you labeled products as having that particular allergen.

This is helpful informaiton to our receivers, compounders, Purchasing, etc. 

 

As for 'May contains' statements, we normally require full disclosure (in a Supplier Survey list) of what product/allergens are run on the line and whether other allergens, and which ones, are also handled in the facility. So, it would not be necessary, as long as we knew what other allergens are handled in your facility.

Does this help?

Suzanne



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