Thanks for the frank response. Some interesting hypothesizing / refs (slightly old maybe). The idea of successively increasing allergen complexity to minimise cross-contamination is not new of course but the logic / use of validatory ref to justify the proposed routine eluded me. My lacking.
Some people think that individual tree nuts should all be different and separate allergens and others think that a tree nut is a tree nut.
My previous posted link suggests that the the consumer viewpoint favours separating tree nuts. Hardly surprising i guess. And perhaps justified.
I doubt that the concept of a clinically non-significant tree nut allergen is validatable except perhaps based on statistical incident data. But such a hypothesis is presumably confounded by its presence in the US, Big 8 list. (other locations may well vary statistically).
It is unclear to me as to the exact power that appropriate labelling wields in the context of ones’s expected degree of rigor regarding cleaning activities, eg is the typical processor required to strictly minimize allergen cross-contamination regardless of labelling “coverage” ? I am guessing it will depend on the situation/product (this is discussed / illustrated in some detail in 2nd,3rd attachments below).
This UK official ref (2006, prob. now revised) suggests that labelling may be a substantial defence -
alg 1 - FSA Guidance allergen management, 2006.pdf 619.9KB
(see Pg 11)(But also see current sec.7.2 of bottom link)
For US I noticed this comment,
The allergen advisory statement cannot be a substitute for poor GMPs. So, if cleaning is can be an effective solution, or if a change in ingredient sourcing prevents the use of an advisory statement, the company would be expected to choose those options. Also, there have been some proposals to add small quantities of non-functional allergenic ingredients to products made on shared equipment or in common facilities. By doing this, the miniscule addition could be included at the end of an ingredient declaration. This is an inappropriate practice if it is designed to circumvent cleaning that could either remove the allergen or at least minimize it to the point of warranting an allergen advisory statement.
alg 2 - Food allergen handling guidance, NCA.pdf 349.67KB
So far I have only seen one processor reference (2013) which contains a clear statement as to their approach regarding different tree nuts (inc. yr mentioned varieties) –
alg 3 - Allergen Management, 2013.pdf 5MB
(see pg 54/104)
(Hopefully yr auditor is procrastination-friendly, or other, tree nut neutral, examples also exist )
Regds / Charles.C
PS - slightly OT but i also noticed this interesting comment -
When applied prudently, precautionary labels can help protect vulnerable consumers. However the unwarranted use of precautionary labels can: i) result in the unnecessary elimination of healthy options from the diet of allergic consumers or ii) reduce their credibility causing vulnerable consumers to take risks with these foods. Regarding the latter, a study of British parents of children with nut allergy found that many either ignored warning labels on foods or assumed that the wording (e.g. 'not suitable for nut allergy sufferers 'versus 'may contain traces of nuts' etc) reflects a gradation of risk.