2.8.2.2 Allergen Management

Hi,

We are a small plant that is SQF level 2 certified. We are in the process of reviewing some of our current policies, practices and procedures. We produce under several HACCP plans in the US including a Raw Ground and Raw Not-Ground.

We use soy in the production of some of our items throughout the day. We have wash, rinse and sanitize procedures in place. My question isn't regarding the use and sanitation procedures as much as it is regarding the SQF policy. 2.8.2.2 that states "The product identification system shall make provision for clear identification and labeling in accordance with regulatory requirements of those products produced on production lines and equipment on which foods containing allergens were manufactured." Does this mean we need to label each item we produce in the facility with a "may contain" or a "produce in a facility" statement?

I'd love to hear your expert and not so expert thoughts.

Thank you

Susan

Hey Susan,

I think you have a good grasp of the situation, unfortunately it means a "produced in a facility/equipment" statement.

Cory

I don't necessarily agree with having to put that statement of "Produced in a facility/equipment..." on your labels.  As long as you are performing clean-up between soy and non-soy products AND that you have verification & validation records proving that your cleaning methods are eliminating that soy protein from the equipment, aren't you covered?? 

If you produce consumer products, you will need to review the FDA requirements for listing potential allergens.