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Advice needed on making allergen declarations

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b.juarez

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Posted 28 October 2015 - 04:43 PM

Hello everybody,

 

 

i have a question on allergens. when producing a product that contains allergens and i need to change to a non-allergen product after doing proper sanitation procedures and CIP cleaning. On my product label i have to declare that the non-allergen product was produced in equipment the also manufactures product that do contain allergen?

 

 

Or for example, i have 3 production lines and i only run allergens in 1 of those lines. do i have to declare on the other 2 non-allergen lines that product With allergens are produced in the same production room or only declare on the particular line that does produce allergen???  

 

 

i am trying to explain as best as i can, not sure if anybody understands. sorry

 

 

please advise

 

 

thanks in advance

 

 

Berenice J

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RMAV

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Posted 28 October 2015 - 05:11 PM

What is the product type and are you dry cleaning or wet cleaning?  Overall, I'm thinking you don't have to declare that you have allergens in your plant on a label that does not contain the allergen(s).


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b.juarez

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Posted 28 October 2015 - 05:45 PM

hi RMAV, it is wet cleaning. its a little confusing so i guess what i am trying to ask is can i just declare   "processed on shared equipment that may have traces of allergens" ?

 

"instead of "Produced in plant that processes allergens" and what is the difference???

 

thanks again


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Charles.C

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Posted 28 October 2015 - 06:04 PM

Hi Berenice,

 

as I understand yr OP, this is a question of "precautionary labelling" in the context of USA.

 

Have a look at this post/thread (there are others, it's a popular topic) -

 

http://www.ifsqn.com...rns/#entry91160


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Kind Regards,

 

Charles.C


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b.juarez

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Posted 28 October 2015 - 06:36 PM

thank you very much  :smile:


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QUALITY22

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Posted 28 October 2015 - 08:43 PM

I work for a frozen dessert company- we have 7 lines and all of our products contain SOME ALLERGEN (DAIRY, WHEAT, SOY, NUTs, ETC) two which run peanut based products from time to time, and 1 they runs peanut/tree nut variegates. We have a 3 step approach when it comes to allergens-

1. Disposable garments on all peanut/tree nut based production lines-(try to run these products end of week only)

2. All customers are required to put -manufactured in a facility with peanuts and tree nuts, even if its not on that line. (this is more of a safety/liability concern) 

3. Validate cip, sanitation, and allergen program annually-PRE OP daily after sanitation

          -validate flow, time and temperature, effectiness of sanitation team

          -swabs sent to FARRP (20 or more per a line on three seperate production runs with the same allergen- all swabs taken before sanitizing after cop/cip


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b.juarez

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Posted 28 October 2015 - 11:03 PM

thank you very much, this is really useful information. i appreciate your time :smile:


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MWidra

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Posted 02 November 2015 - 08:33 PM

All good advice.  What is important to remember is that, in the US, you only have to say what IS in the food. 

 

If you want to say that it is manufactured in a plant where an allergen is present, or that it's made on machinery that also processes allergen XXX, then you are trying to protect yourself from a possible lawsuit.  That's not a bad thing.  But the other side of that coin is that some people may not buy the product just to be safe.  So there's a potential to lose customers if you put on those precautionary statement if they are not needed.

 

Only you know how much risk there is of cross contamination.  You may want to use some kind of rapid check for allergens in your plant to back up statements made on your labels.

 

Martha


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b.juarez

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Posted 02 November 2015 - 09:57 PM

Hello MWidra

 

You have made it supper clear to understand, i was having a hard time trying to explain myself when i posted my question. i really appreciate your feedback  :spoton:


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