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Incidental Agricultural Cross-Contact

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Posted 28 July 2017 - 10:51 PM

Hi all,


I wanted to ask what have been some of your practical experiences with certain commodities having detectable levels of allergenic material due to cross-contact / co-mingling at the agricultural level.


What are common commodities that would have detectable levels of other allergenic material??Examples I have would be oats that may contain detectable levels or wheat and soy. I'm wondering if there is a matrix out there with co-mingling risks of certain commodities to be used for risk assessing new materials?


As it is not required to be label, many times agricultural co-mingling doesn't present itself unless the supplier provided a statement letter or through testing down-steam



The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) specifically excludes raw, agricultural commodities from labelling requirements prior to arriving at raw material suppliers’ facilities for processing. 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.[1]

[1] Guidance for Industry: Questions and Answers Regarding Food Allergens, including the Food Allergen Labeling and Consumer Protection Act of 2004 (Edition 4); Final Guidance (https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ucm059116.htm)


USDA allows certain grains, and has established for those grains, standards that allow for contamination of other grains to be present include barley, canola, corn, flaxseed, oats, rye, sorghum, soybeans, sunflower seed, and triticale (USDA, 2004). Before the removal of dockage (all matter other than the desired grain that can be removed), up to 25% of other grains are allowed in oats and barley, 20% in flaxseed, and 10% in corn, canola, soy, sorghum, rye, sunflower seed, and triticale (USDA Grain Inspection Handbook).


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Posted 30 July 2017 - 02:08 AM

Hi Maillard,


In fact there are a few older co-mingling threads here on this topic, IIRC mainly in a US context.

The subject also legally overlaps "adulteration", another favourite US "bête noire."

And reappears in GMOs and Gluten-free discussions.


As per yr post, the Global handling mostly seems to devolve down to the issuance of certain Regulatory (arbitary?) tolerances to quantify acceptable deviations. Canada from memory has some particularly detailed viewponts regarding wheat, oats etc allergenicity.

Kind Regards,



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