Tony-c my question is regarding this clause also; 21 CFR Subpart O, "Sanitary Transportation of Human and Animal Food"
21 CFR Subpart O 1.908
(ii) Taking effective measures such as segregation, isolation, or other protective measures, such as hand washing, to protect food transported in bulk vehicles or food not completely enclosed by a container from contamination and cross-contact during transportation operations.
Beverages are completely enclosed by their container so these industries are exempt from Subpart O, however there is the clause above. My issue is that FDA inspectors (dairy, etc) will insist that we still need allergen identification and denoted as spill-preventive on route to markets (e.g., hy-vee, walmart, etc).
Edited by jdpaul, 18 March 2019 - 11:19 PM.