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#1 adamperry2235

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Posted 10 January 2017 - 03:43 PM

My current labels identify wheat as being a potential allergen in every one of my products. My SQF auditor said that was not ok because I was not able to prove that there was wheat in everything, even though I constantly stand the risk of cross contamination. What should be my approach to this on the label? Is putting "produced in a facility that handles wheat. May contain wheat" going to be acceptable?



#2 LoredanaM

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Posted 10 January 2017 - 04:39 PM

You have to conduct a risk analysis for each product; I will advice to research statements handled by other companies for products similar to yours.

One suggestion though - SQF, as any other quality management system is looking for continuous improvement, so my suggestion is to look into reducing the possibility of cross-contamination (warehousing, production planning, etc.)



#3 GMO

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Posted 10 January 2017 - 05:05 PM

Ah "may contains".  Hate it.  My son has a nut allergy and the amount of stuff which allegedly contains nuts is shocking.  That said, I went to a copackers recently who were packing nuts, doing a dry clean then packing pasta on the same line!  :eek_yello:

 

Despite all my years in the food industry I never expected that!

 

I agree with the previous poster, risk assess, risk assess, risk assess.  What is the genuine risk of cross contamination between your wheat and non wheat products.  Now, and here's the important bit, even if you chose to put a disclaimer on pack, you should still try and minimise the risk of cross contamination as much as you can.  Not sure about US legislation but in the UK if you put "may contains" on a product but it actually contains a detectable level which isn't listed as an ingredient, you are still on the wrong side of the law anyway buddy.  The disclaimer statements are comforting to manufacturers but most allergenic consumers ignore them.

 

So now I've taken you out of the cosy world where the warning isn't worth the packaging it's written on, what do you do next?  Well you look at various things you can do to control the wheat.

 

Where is it stored?

Where is it weighed out?

What form is the allergen in (light powders can be a pain for example).

What can you do to control the spread of the allergen?  Do you need specific weighing equipment, PPE etc?

Where are the hot spots where contamination is difficult to control?  They might be where the allergen is most concentrated and in a form like liquid or powder where spillages could be likely.

Where do you use shared equipment?

Can you plan to do non wheat before wheat containing lines (if you have an end of day clean)?

If you have to do wheat before non wheat, how do you validate your cleaning (e.g. ELISA swabs, ELISA testing of the positive control containing wheat and the first few products of non wheat to prove no cross contamination?)

Can you use rapid swabs post clean if they'd add value to your process?  This might be a good idea if you are this wary.

 

Only after all of that control and working on improving it would I still then say you're doing everything you can to stop cross contamination. Even if you and your bosses aren't brave enough to remove that warning, you are still doing everything you can to protect a vulnerable consumer who is fed up with everything they pick up saying "may contain".



#4 Scampi

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Posted 10 January 2017 - 05:56 PM

I just want to add my two cents to the discussion as a manufacturer of a product that does carry a "may contain" statement (because they do have their place) But i do agree with PP, you do need to investigate why you cannot with certainty claim that you have not cross contaminated at least some of your products

 

we produce RTC poultry of a species that lays eggs very young relatively speaking.....and as a result, we CANNOT declare our poultry to be egg free, neither can we change the process and definitely not the physiology of the species to remove the possibility of immature egg rupture during production so all of our product is labelled "may contain egg"


Because we always have is never an appropriate response!


#5 adamperry2235

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Posted 10 January 2017 - 06:14 PM

We do our best to minimize cross contamination but we are a flour mill that produces mainly wheat products. Being organic also cuts down on the cleaning products we can use. So our best option is to label. And Ive talked to the FDA about this, and much like the IRS you get 3 different answers from 3 different people. Thanks for the input!!



#6 Scampi

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Posted 10 January 2017 - 08:28 PM

Then perhaps for the auditor, you need a written version of why you cannot be sure products are allergen free....eg test swabs after a clean out etc that repeatedly show that despite your best efforts the wheat is always present


Because we always have is never an appropriate response!


#7 Charles.C

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Posted 11 January 2017 - 07:21 AM

To answer GMOs US query (post3), I think there are several older posts which categorically state that FDA are on record as expecting all necessary measures to be implemented so as to minimise cross-contamination regardless of labelling. IIRC FARRP publications are quoted regarding such issues.

 

i appreciate this may be contrary to comments in post 5 but one can imagine the consequences if the requirements were truly "freestyle".


Kind Regards,

 

Charles.C


#8 CMHeywood

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Posted 12 January 2017 - 04:01 PM

FALCPA does not require "may contain..." but it is common practice if there is a chance of cross contamination.



#9 Ryan M.

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Posted 13 January 2017 - 09:22 PM

To answer GMOs US query (post3), I think there are several older posts which categorically state that FDA are on record as expecting all necessary measures to be implemented so as to minimise cross-contamination regardless of labelling. IIRC FARRP publications are quoted regarding such issues.

 

i appreciate this may be contrary to comments in post 5 but one can imagine the consequences if the requirements were truly "freestyle".

 

Yes.  The FDA expects manufacturers to provide the necessary measures to control allergen cross-contamination.  Basically, if you manufacture multiple allergens on the same equipment you need to do your best to control the cross allergen contact.  Just slapping on a "May Contains" statement on the packaging and not having controls or insufficient controls is not sufficient in the eyes of the FDA.  

 

However, note that the "May Contains" statement can hold water legally in the US.  At least, this is what was discussed in a labeling workshop I attended with a food lawyer speaking on the allergen labeling portion.  I specifically asked him if a company has a "May Contains" on their label of XX product and a person with that allergy has a reaction after consuming is the company legally liable?  He said the company would not be found liable 9 times out of 10.  I then jokingly said, "Well our company has 8 allergens in our facility that have contact with all equipment.  I guess we can just put a "May Contains" on everything and be ok."  He said that would work, but it would also severely limit our customer base.






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