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Can Feed Grade material run on equipment lines that make Food Grade?


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#1 markny41

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Posted 04 April 2014 - 05:13 PM

Hi,

 

Can Feed Grade material (i.e. Flavor Enhancers) be processed (run) on equipment lines that make Food Grade? (i.e. Dietary Supplements)  or should Feed Grade be processed only on dedicated lines?

 

I want to say NO, Feed Grade should only be processed on dedicated lines.  I am looking for a definitive answer if someone can point me in the right direction for guidance I'd really appreciate it.  Thanks.

 

 

best regards,

 

Mark



#2 Mr. Incognito

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Posted 04 April 2014 - 05:23 PM

What kind or product and system are you working with?

 

I would say if it can be thoroughly cleaned after the feed grade product so that it does not contaminate the food grade then yes... I would think.

 

Unless you kosher.


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#3 markny41

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Posted 04 April 2014 - 06:34 PM

What kind or product and system are you working with?

 

I would say if it can be thoroughly cleaned after the feed grade product so that it does not contaminate the food grade then yes... I would think.

 

Unless you kosher.

Thanks Merle I'd have to double check if it's Kosher...it's a contract manufacturer that we are looking at using that currently manufactures Animal Feed.  My company is a Dietary Supplements company.  I'll have to examine their cleaning procedures. 



#4 Mr. Incognito

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Posted 07 April 2014 - 12:02 PM

Hold on...

 

Is the equipment food grade or non-food grade?

 

And while we are at it... who is your regulatory body (FDA I'm guessing) and your inspecting body.

 

Have you read over this:

 

http://www.fda.gov/F...s/ucm238182.htm

 

and other FDA related documentation?  This is, AFAIK, the current GMPs required by the FDA for your industry.  I didn't see anything specifically saying you couldn't do it... but I can't spend all day reading it either lol.


Edited by MerleW, 07 April 2014 - 12:16 PM.

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#5 markny41

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Posted 14 April 2014 - 06:18 PM

Hold on...

 

Is the equipment food grade or non-food grade?

 

And while we are at it... who is your regulatory body (FDA I'm guessing) and your inspecting body.

 

Have you read over this:

 

http://www.fda.gov/F...s/ucm238182.htm

 

and other FDA related documentation?  This is, AFAIK, the current GMPs required by the FDA for your industry.  I didn't see anything specifically saying you couldn't do it... but I can't spend all day reading it either lol.

Thanks Merle,

 

Our facility is a Food Grade facility and FDA is our regulating body.



#6 Charles.C

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Posted 15 April 2014 - 06:29 AM

Dear markny,

 

Unless there is a specific local regulatory requirement (eg FDA) / industry best practice etc restriction on the idea, it usually comes back to risk assessment.

 

More specifically, can you validate that the line after use for feed material is then appropriate for food grade product ?

Do you even know how to validate such a requirement ? :smile:

As a partially comparable example you might consider the control requirements for allergenic/non-allergenic materials running on the same line. This has only one variable involved, albeit a potent one.

 

I have occasionally encountered related scenarios regarding re-use of treated/analysed wastewater. Sooo tempting to recycle but equally so potentially contentious. I audited one factory which had just had a strike after it was discovered that the highly treated effluent wastewater was subsequently being officially used for the in-house vegetable garden. And eventually served back at lunchtime. The perfect closed system perhaps. Rapidly discontinued after the consumer backlash. :smile:

 

Offhand, yr idea sounds to me like a simple "best avoided" zigzag unless you have a rock-solid scientific backup/justification.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C





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