I am in a quandary. We are processing oats, which are inherently non-allergenic (no gluten in oats)...however, the very nature of oat production, especially in regards to storage and transportation practices from farm to grain elevator, shows that there is a history of, and therefore a potential for, cross-contamination with other grains through incidental/accidental/residual mixing or other contact.
We are going to be starting off our production as livestock feed-grade only, but plan to transition to pet food grade and then to human food grade.
My question is simple, yet somewhat complex when you drill down on it: If we don't use any ingredients that are inherently allergenic, and don't have any other allergenic substances in our facility, do we still need to have an allergen swabbing/sampling program?
The answer is obviously no if we're simply making animal feed, but when we transition to pet food, and then food-grade, it becomes much more difficult to answer.
We are making no claims of being organic, gluten-free, or anything else like that on our labels.
Oat products may contain adventitious barley, rye, wheat and triticale from the grain handling process as allowed by the U.S. Grain Handling Standards and the Canadian Grain Commission. According to the latest Q&A Document released by the FDA December 12, 2005, labeling of allergens from cross-contact is not required. FALCPA's labeling requirements do not apply to major food allergens that are unintentionally added to a food as the result of cross-contact. In the context of food allergens, “cross-contact” occurs when a residue or other trace amount of an allergenic food is unintentionally incorporated into another food that is not intended to contain that allergenic food. Cross-contact may result from customary methods of growing and harvesting crops, as well as from the use of shared storage, transportation, or production equipment.
So, putting all of that together...what are your thoughts??