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Is a release agent considered a processing aid?

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idealdreams

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Posted 09 April 2018 - 03:53 PM

Howdy all. We use a cooking spray as a release agent in our process to prevent work-in-progress from sticking to our equipment. The SQF Code states that specs for all raw and packaging materials, including, but not limited to ingredients, additives, hazardous chemicals, and processing aids shall be documented and kept current (2.3.2.1).

 

Does a release agent fall into the processing aid category or is it something separate? In the past, we have been told by auditors that because the cooking spray is used as a release agent, we don't need to maintain specs for it nor traceability, however in our most recent audit last week, we received a non-conformance for this in two places.

 

Any clarification is appreciated!



FurFarmandFork

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Posted 09 April 2018 - 04:49 PM

It's an ingredient you're directly adding to food, it absolutely should have a specification. It's an ingredient to you, the "processing aid" distinction only has implications on the labeling of the final product, not on it's impact on your product's safety/quality.


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Scampi

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Posted 09 April 2018 - 05:08 PM

Perhaps these shall help (but it should still be coming from an approved supplier whether its a processing aid/additive or ingredient).  I would handle it as a processing aid by definition

 

https://www.canada.c...ds-2008.html#a3

 

https://www.accessda....cfm?fr=101.100

 

Then you can clarify in your program exactly what the release agent is for and why is comes from an approved supplier but IS NOT on the ingredient list----part of the caution will be is it a nut or palm based formula and therefore a possible allergen


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SQFconsultant

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Posted 09 April 2018 - 08:49 PM

This is what happens when you take advice/suggestions from Auditors.

 

It is an additive/ingredient.

 

You must have full specifications for it.


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redfox

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Posted 10 April 2018 - 07:34 AM

Hello,

 

All the things that go into production, including packaging must have a specification and traceable. So much so on the releasing agent (processing aid) that would come in contact of your product. Even the food grade grease has the specification and must be traceable, and it it required that there must be a certification that it is made in an allergen free environment.

 

regards,

redfox



idealdreams

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Posted 10 April 2018 - 01:30 PM

Thanks for the input everyone. I have the spec coming to me this week to resolve this NC and will be sure to make it clear that specs are required for items like this going forward.



scoot915

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Posted 11 April 2018 - 10:50 PM

You did not mention if you list the processing aid in your product as a ingredient.

If you do, you can stop reading... lol   

If not, I thought I would add what we do.

 

For our processing aid/s (oil and a spray release product) we have specs, supplier approval and traceability.

 

At the end of the list of ingredients in the product we write "Processing aid:" and then the list of ingredients in the processing aids.

A customer wanted it this way a few years back.  So far, no auditor or inspector (FDA) has commented on this one way or the other.

 

And watch out for allergens.....

One of the oils and the spray release product we use contain soy, which is a allergen. 

Our products contain soy so this is not a unique allergen for us.

If soy is NOT in your product but IS in the spray release, I think you need to at least list soy in the ingredients and have  "Contains: soy" on your product.

 

hope this helps



moskito

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Posted 15 April 2018 - 10:47 AM

Hi,

for the EC

- yes it is a processing aid,but becomes part of your product (food)

  -> you need full specification and full traceability because it has to fulfill food standard requirements
  -> have look on carry over definition, especially if the processing aid is a mixuture of several substances

- you don't need to declare in the list of ingredients if no allergen is part o the processiong aid
- if the processing aid is allergenic declaration is mandatory.

 

Rgds

moskito



Gerard H.

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Posted 15 April 2018 - 07:50 PM

Hi Idealdreams,

As Moskito says, the fact of not labeling doesn't liberate you from other applicable legislation and certification requirements.

It's important to know all the processing aids in your process, as well as the ones in your raw materials. Such an approach keeps you far from nasty issues or even blocked goods.

Good luck with the resolution of these non-conformances.

Kind regards,

Gerard Heerkens





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