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Stating "Nut Free Facility" on packages


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#1 irndiaz

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Posted 06 April 2015 - 05:26 PM

Hi everybody! I would like some help on the following situation: The Purchase Manager in the company brought up a new idea for our packages, he would like to add NUT FREE FACILITY on them. We are a nut free facility, does somebody know if we would have any issues adding this statement in our packages. Thanks, IRN



#2 teaks

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Posted 06 April 2015 - 06:13 PM

What EXACTLY does nut-free mean to you?



#3 xylough

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Posted 06 April 2015 - 07:22 PM

Hi IRN,

 

Looks like this is your first post to the IFSQN ever. In order to give a well focused, appropriate answer to member questions it's helpful to have at least some minimal background. on your facility and products. You have posted in the BRC/food packaging topic area; is your facility BRC certified?

What product categories do you produce? What jurisdiction(s) are you under, FDA, USDA? County health department? 3rd party audits? GFSI standards? Customer Standards?

 

I have to take ksullivan's rhetorical question to heart and answer that "nut-free" is wide open to interpretation. It has no science, legislative or standard based definition. Part of the mission of both USDA and FDA is to combat misinformation and claims which cannot be substantiated.

 

I'm asking myself other questions:

 

What is the risk/hazard that your ingredients and components from your suppliers have been contaminated before or while they are shipped to you?

Are you certain your distributor does not contaminate your goods as they are shipped out to your customers?

Have you read the list of tree nuts in FALCPA guidance for industry?

Do you have controls to verify the absence of tree nut allergens in your processes.

Do you control what your employees bring into your facility for meals, snacks etc.?

Is the business risk of recall worth the perceived advantage of making this undefined claim?

Have you vetted the idea with your company's label law firm?

 

Regards



#4 Mulan1010

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Posted 14 April 2015 - 06:07 PM

xylough brings up some great questions that you need to be able to be able to answer and support.

  First question is will the label claim help maintain and increase sales enough to offset all the additional work required?  If yes, then....

  Controls of employee's meals and snacks - you will want to have written procedures in place on how you will control them from being cross-contacted into your production areas along with documented training for this and internal audits verifying this.  You will want this in place regardless of label claim to support you hazard analysis on allergens.

  Suggest you start with suppliers and obtain letters from each one stating that nuts (of any kind) are not in their products with support of why.  A documented outside audit for each supplier that verifies this is highly recommended.  If suppliers can not make this claim for you ingredients then there is no use to go any further until they can.

    Bottom Line - Ensure you can fully support your claim.  "Label Claims" are very popular in the USA at this time and it makes work that much more challenging, although it can be done with the proper research, documentation, training, verification and validations. - Good Luck!



#5 shea quay

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Posted 14 April 2015 - 11:12 PM

Ah! The "Purchasing Manager". No doubt new, and full of new ideas for the easy win and the USP (unique selling point) in the tough, competitive market. 

 

First point - applaud the new purchasing manager's idea! What a great idea! Why didn't anyone think of this before! That marketing course he/she did was money well spent!

 

Second point - oh, but we need may to verify this, I can tell by your thick head of hair that you have never had to think about consequences before. 

 

Third point - hey MD! I see you are enjoying a nice Snickers bar right there - just wanted to talk to you about something. It involves my chemical testing budget and our marketing budget. 

 

Fourth point - Writing the 'so long' card - "miss you already. You don't have to be nuts to work here, but it helps!!!!" 

 

If you require any further assistance on how to deal with workplace bullies, please feel free to pm me. 






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