Hi all, I am working in an grain and legume company. Our situation is that due to farming practices (crop rotation), we often (or always) find cross contamination (from a few kernels to sometimes a few percent)of wheat in certain varieties of products. It is also impossible to clean out all the wheat due to the same density and kernel size. According to United State FDA regulation, Wheat is considered a major food allergen, and shall be labeled if it is an "Ingredient" within your product. It also defines "Cross-Contact" but not "Cross Contamination". So my questions is regarding labeling law, if it is regulated to label “Contains Wheat” if it is cross contamination from the field not part of the ingredient? What is everybody's thought and if anybody has a better understanding of FALCPA requirements. Thank you!
Posted 02 May 2014 - 06:07 PM
We make flour and we have a slight cross contamination of soy due to the same type of field issues you have. If we see whole soy beans in the wheat we reject the shipment but otherwise we send out samples for soy testing every few months but it's not on our product.
That being said we don't sell our product at market it goes to other manufacturers and bakers... so I'm not sure. I think if it's incidental non-ingredient contamination, like you described, you may be able to put may contain soy. I tried to look up max amounts of cross contamination for labeling and all that before but I couldn't find anything concrete within FDA or anyone else's documentation.
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Posted 02 May 2014 - 06:21 PM
Thank you for your information Mr. Incognito, our major issue is that it is such a common practice we are unable to reject loads that are contaminated or else we will have no ingredients... FDA really doesn't have a clear guidance on this issue.
Posted 02 May 2014 - 09:35 PM
I'm not in USA but I would have anticipated that the most likely criteria for FDA/FALCPA regulatory labelling would be based on consumer Food Safety rather than the origin of any ultimate allergenic content.?
I deduce you are proposing there is some terminological difference between "cross-contact" and "cross-contamination". Perhaps you could elaborate as i find it difficult to visualize the difference.
You may find this contextually related but different allergen thread of interest -
Rgds / Charles.C
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