6 replies to this topic

[GSH19]

Hi All,

I have a question about implementing allergen program for suppliers and customers who don't have allergen program. One of our biggest customer does not consider as celery seeds, mustard seeds, tree nuts as allergens although they have all kinds of certifications.  All of their raw material (including non allergen raw materials) comes to us for processing and packaging. Should we treat all of their products as allergens since there is chance of cross contamination?

I am wondering what percentage of population are allergic to celery, mustard and other products? Isn't it too much regulations for small  manufacturers?

[Charles.C]

Dear GSH19,

 

Is yr "big customer" query from (1) a purely allergenic POV or (2) a labelling / legalistic POV ? Or ?

 

If (1) it's a question of your risk assessment of your cross-contamination. or perhaps you prefer the Precautionary Principle?.

 

If (2) its a question of local legislation and i believe the USA is "quirky".

 

But presumably you would anyway implement an allergen program since i  presume there will be a risk of cross-contamination for other (caring?) customers also.?

 

Rgds / Charles.C

[fgjuadi]

1) Yes, you should have an allergen control program.  In the US, the allergens you control for are the big 8.  Celery and mustard are not in the big 8, so legally you don't have to control them if you only sell to the US. 

 

You must find out which products contain which allergens to allow proper line cleaning, and this includes tree nuts.  Your customer may not control for tree nuts because tree nuts are present in all of their products.  Even if all of their products contain tree nuts and are labelled that way, some of your other customers might not use that allergen, so you have to clean lines, etc to avoid cross contamination.   The easiest & least expensive way to figure out if something is an allergen is to get an ingredient list or allergen statement.  A (much) more costly and time consuming way to get it is to test each incoming ingredient for each allergen.  

 

2) Allergens develop at different points in your lifetime, and affect populations differently.  For the US, here's a totally untrustworthy "fact sheet"  - http://www.webmd.com...ergy-statistics

 

3) Basically, by controlling allergens, you're making sure you don't accidentally kill someone.  I don't think that's too much to ask of a business, big or small.

[agasr]

Hi -

Apart from the above comments with which I totally agree, another worthwhile exercise would be to contact them (better yet visit/audit them) & understand their Storage policies of these materials.  The interest is to understand the segregation principles employed & the risk profile they must have assigned to each of those material. That might give you some insight into their practices or the lack thereof on allergen management & cross contamination prevention programs such as Spill control, cleaning/sanitation at their end.

Based on that you would be in a better position to request the necessary changes in their layout, practices to better protect your interests & consumers.

I hope this pov is helpful in some ways in coming up with a policy that is difficult to accomplish even in the best of the scenarios.

 

Regards,

[GSH19]

Hi -

Apart from the above comments with which I totally agree, another worthwhile exercise would be to contact them (better yet visit/audit them) & understand their Storage policies of these materials.  The interest is to understand the segregation principles employed & the risk profile they must have assigned to each of those material. That might give you some insight into their practices or the lack thereof on allergen management & cross contamination prevention programs such as Spill control, cleaning/sanitation at their end.

Based on that you would be in a better position to request the necessary changes in their layout, practices to better protect your interests & consumers.

I hope this pov is helpful in some ways in coming up with a policy that is difficult to accomplish even in the best of the scenarios.

 

Regards,

Thanks for the information. I am not sure whether we can audit our customer?  Celery seeds, mustard seeds are considered as allergens in the US, but it is  still our duty to prevent cross contamination to products of customers 

 

Dear GSH19,

 

Is yr "big customer" query from (1) a purely allergenic POV or (2) a labelling / legalistic POV ? Or ?

 

If (1) it's a question of your risk assessment of your cross-contamination. or perhaps you prefer the Precautionary Principle?.

 

If (2) its a question of local legislation and i believe the USA is "quirky".

 

But presumably you would anyway implement an allergen program since i  presume there will be a risk of cross-contamination for other (caring?) customers also.?

 

Rgds / Charles.C

Thank you Charles,

Should we consider all of their product as contaminated with allergens?

 

Dear GSH19,

 

Is yr "big customer" query from (1) a purely allergenic POV or (2) a labelling / legalistic POV ? Or ?

 

If (1) it's a question of your risk assessment of your cross-contamination. or perhaps you prefer the Precautionary Principle?.

 

If (2) its a question of local legislation and i believe the USA is "quirky".

 

But presumably you would anyway implement an allergen program since i  presume there will be a risk of cross-contamination for other (caring?) customers also.?

 

Rgds / Charles.C

 

products in Canada, Europe, etc.

[GSH19]

1) Yes, you should have an allergen control program.  In the US, the allergens you control for are the big 8.  Celery and mustard are not in the big 8, so legally you don't have to control them if you only sell to the US. 

 

You must find out which products contain which allergens to allow proper line cleaning, and this includes tree nuts.  Your customer may not control for tree nuts because tree nuts are present in all of their products.  Even if all of their products contain tree nuts and are labelled that way, some of your other customers might not use that allergen, so you have to clean lines, etc to avoid cross contamination.   The easiest & least expensive way to figure out if something is an allergen is to get an ingredient list or allergen statement.  A (much) more costly and time consuming way to get it is to test each incoming ingredient for each allergen.  

 

2) Allergens develop at different points in your lifetime, and affect populations differently.  For the US, here's a totally untrustworthy "fact sheet"  - http://www.webmd.com...ergy-statistics

 

3) Basically, by controlling allergens, you're making sure you don't accidentally kill someone.  I don't think that's too much to ask of a business, big or small.

Hi Magenta,

Thank you for the info. Although celery and mustard are not in the big 8 list in the US, Canada and other countries consider them as allergens. There are more items such as cocoa, coconut, and etc in the list from other countries. What are we supposed to do when our products are sold all over the world?

[Charles.C]

Dear GSH,

Thank you Charles,

Should we consider all of their product as contaminated with allergens?

 

 

This is logically where the Raw Material Specification comes in.

And your Finished product Specification.

And your customer. And his location.

 

AFAIK some Companies implement a Global Policy based on their own risk assessed relevant allergens, result can be a longer list than the minimally required local legislation. Others base it on the local/destination regulatory labelling requirements. The decision may obviously overlap a variety of issues, regulatory, ethical, commercial, etc

 

IIRC, the USA food labelling requirements do permit some (debatable?)  exceptions, eg

 

http://www.fda.gov/f...s/ucm079311.htm

http://www.kidswithf...espre.php?id=50

 

And probably many (most?) other locations also.

 

Rgds / Charles.C