Labeling Considerations in Food Safety Plan for Allergens
We produce a product with mustard seeds in the US and ONLY ship this specific product to Canada. We are SQF certified and are finishing up our new Food Safety Plans. I was wondering how some of you have handled a situation like this in your FSP's Allergen Controls section since the allergen is recognized in the destination country only . Do you discuss any scheduling or cleaning implications, ingredient analysis, or labeling concerns?
I was thinking we could simply note these products that specifically ship to Canada and the allergen is unique to that country so our main concern would be correct labeling which is handled in our usual label review process. Our cleaning, scheduling, and storage implications would remain the same as they are for our other allergens. Any thoughts? Am I missing anything that could get us dinged with FDA?
I think you are on the right track. SQF does require that you maintain some sort of list of regulations that apply to your product. The list needs to include the regulations of the country where produced and where used. You have more of an SQF issue than an FDA issue, in my opinion.
What specifically are you talking about regarding the SQF regulation list? Just trying to make sure I am on the same page.
Section 2.4.1 Food Legislation (Regulation) - Manadatory
2.4.1.1 The organization shall ensure that, at the time of delivery to its customer, the food supplied shall comply with the legislation that applies to the food and its production in the country of its origin and destination. This includes compliance with legislative requirements applicable to maximum residue limits, food safety, trade weights and measures, packaging, product description, nutritional, allergen and additive labeling, and to relevant established Industry codes of practice.
This implies that you have a list of what legislation and regulations apply to the product in its country of origin and its country of destination. Without the list, you are relying on memory as to what legislation and regulations you need to review for compliance.
The auditor will seek evidence of the existence of information on applicable legislation and of a procedure for maintaining currency of food regulations.
Evidence may include:
Review of the procedure to maintain and update legislative requirements;
• Applicable legislative requirements have been incorporated into specifications (refer 2.3.2, 2.3.5);
• Applicable legislative requirements are being applied and being inspected and/or tested (refer 2.5.6);
• Compliance with legislation is checked as part of internal audits (refer 2.5.7) and the management review (refer 2.1.4.2).