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#1 majoy

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Posted 28 August 2017 - 03:52 PM

We have a new product development that is almost approved. However, when paper works were forwarded to me, I found out that one raw material has a "May contain sesame seed" statement in the specification.

 

We do not have sesame seeds in any of our product, raw materials, packaging and in storage. This will be an introduction of a possible new allergen in the facility.

 

I called the manufacturer to inquire the risk of contamination of sesame seeds, I was informed that they produced products with sesame seeds on the same line, however, they have allergen management procedure to ensure no cross-contact of allergens. And the products with sesame seed allergen is not run as frequent on their line and they can manage through production scheduling and cleaning.

 

How do you guys handle this may contain presence of an allergen in your raw material? Do you declare this in your product just so there is precautionary statement to consumers? or a risk assessment is acceptable for us to go away with declaring the sesame seed as may contain in our product?

 

Appreciate an idea on how to go about this.


"Whatever you do, do it well..." - Walt Disney


#2 Andy_Yellows

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Posted 29 August 2017 - 06:22 AM

Hi Majoy, would it be feasible to send a member of the food safety team to the supplier's premises? Or failing that maybe you could request that periodic lab micro-testing of their product for sesame presence is undertaken? Either way you could probably sidestep the "may contain sesame" with "produced in a facility that also handles sesame" or something of that nature.

 

Hope this helps

 

Andy


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#3 Gerard H.

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Posted 29 August 2017 - 08:59 AM

Dear Majoy,

 

Indeed, a supplier audit on place, to see how serious this supplier is with its allergen policy.

 

Afterwards, I would make an appendix of the supplier contract, mentioning the measures taken by the supplier, to deliver you a product free of the allergen sesame.

 

Furthermore, each delivery will be accompanied with an analysis certificate, stating that the product is free from sesame.

 

If your supplier shows no cooperation, you should consider a supplier switch.

 

Kind regards,

 

Gerard Heerkens



#4 Wer3005

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Posted 29 August 2017 - 11:32 AM

HI, What do you think to ask suplier for the Vital assesemnt of the possible seasme level in raw material?



#5 majoy

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Posted 29 August 2017 - 01:18 PM

The supplier is GFSI SQF level 2 certified so, my protocol states that on-site audit can be waived if the supplier is GFSI certified. Although, I may have to make exemption on this supplier.

 

I should also ask a letter from this supplier stating how they manage allergen and what are the measures to ensure that our products will be free from sesame seeds. Should this be sufficient to get away with us declaring the may contain sesame seeds in our products? And if i scheduled a dedicated day of production for this product, will this also help me lower the risk of cross contact if there will be any?


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#6 Gerard H.

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Posted 29 August 2017 - 01:50 PM

Dear Majoy,

 

The thing which raised my haires, is that instead of mentioning "May contain traces" of the allergen, the supplier had stated "May contain" the allergen itself. By doing so, it's almost a part of the ingredients declaration and the supplier denies any responsibilty.

 

By mentioning "may contain" on your product, you are taking over the responsibility (read: the problems) of your supplier.

 

There are some steps to take. Just before the launch of a new product, that's not easy. But try to do the maximum and you will benefit later. For example during future audits. As it is a new product (and with allergens), it will always be in the spotlight.

 

What you need to avoid in any case is a recall, because of bad labelling. What you also can do is start with a small label stock for the first months (stating the "may contain" and resolve this issue in the meanwhile).

 

Kind regards,

 

Gerard Heerkens



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#7 majoy

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Posted 29 August 2017 - 02:14 PM

Dear Majoy,

 

The thing which raised my haires, is that instead of mentioning "May contain traces" of the allergen, the supplier had stated "May contain" the allergen itself. By doing so, it's almost a part of the ingredients declaration and the supplier denies any responsibilty.

 

By mentioning "may contain" on your product, you are taking over the responsibility (read: the problems) of your supplier.

 

There are some steps to take. Just before the launch of a new product, that's not easy. But try to do the maximum and you will benefit later. For example during future audits. As it is a new product (and with allergens), it will always be in the spotlight.

 

What you need to avoid in any case is a recall, because of bad labelling. What you also can do is start with a small label stock for the first months (stating the "may contain" and resolve this issue in the meanwhile).

 

Kind regards,

 

Gerard Heerkens

 

 

My CEO won't be happy with declaring new allergen and reassessing our system to include this allergen but this will all save us too just in case. I know most manufacturers chose to over declare instead of under declare, the risk is higher for a recall.

 

Yes, i do understand that auditors love to check on everything "NEW" - new employees, new products, new processes etc, so this will always be a highlight during audit if this product is launched.

 

Thanks for the input.


"Whatever you do, do it well..." - Walt Disney


#8 Gerard H.

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Posted 29 August 2017 - 02:38 PM

Hi Majoy,

 

You're welcome! I hope that all the advice above can help you to sort this out and to take the right decisions. Hopefully, there will be more members in the coming hours with their helpful tips.

 

Kind regards,

 

Gerard Heerkens



#9 Charles.C

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Posted 29 August 2017 - 08:04 PM

We have a new product development that is almost approved. However, when paper works were forwarded to me, I found out that one raw material has a "May contain sesame seed" statement in the specification.

 

We do not have sesame seeds in any of our product, raw materials, packaging and in storage. This will be an introduction of a possible new allergen in the facility.

 

I called the manufacturer to inquire the risk of contamination of sesame seeds, I was informed that they produced products with sesame seeds on the same line, however, they have allergen management procedure to ensure no cross-contact of allergens. And the products with sesame seed allergen is not run as frequent on their line and they can manage through production scheduling and cleaning.

 

How do you guys handle this may contain presence of an allergen in your raw material? Do you declare this in your product just so there is precautionary statement to consumers? or a risk assessment is acceptable for us to go away with declaring the sesame seed as may contain in our product?

 

Appreciate an idea on how to go about this.

 

Hi majoy,

 

Not sure about Canada but based on previous related threads here, I predict the typical US response to yr penultimate paragraph in OP will be Precautionary  YES, absolutely !.

Unless perhaps the inclusion will make the specific product negatively stand-out from competitors for some reason. (Unlikely if in microscopic print).


Kind Regards,

 

Charles.C





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