Walnut Hand Scrub and "Tree Nut" Allergen Statement?

Hello, My facility is currently looking into a new, more effective hand scrub that contains walnut. Our facility already processes tree nuts (coconut, which is considered a tree nut in the US), so we have a "contains tree nuts" allergen statement. My question is, if we add this walnut hand scrub, would it pose an allergen cross contamination issue if we already have that allergen declared on the label? The fact that the declaration is "tree nuts" and not "walnuts" specifically is what's throwing me off.

Any advice is greatly appreciated! Thanks so much for your help :) 

My first thought........what are you making that you need an exfoliating hand scrub???

It would appear no issue labeling wise

from the FDA..."The following are considered "tree nuts" for purposes of section 201(qq). The name listed as "common or usual name" should be used to declare the specific type of nut as required by section 403(w)(2)."

However, I would do some swabbing first on folks hands..........and the scrub really should be followed up with a normal hand soap 

There is another thread here on shell scrubbers. The potential impact is nil.  The shell fragments are for all intents and purposed completely sanitized of allergen - which for the most part is the meat of the walnut and not the shell anyway.  There should not be an issue here.  The shell scrubbers make for excellent scrubbers, but at a cost and for some a potential irratant.

In the US the use of the "contains tree nuts" label in NOT legal.  You need to declare the actual nut:  "Contains coconut".

As far as the walnut issue, you are correct that you need to consider cross-contact.  You need to document that the hand scrub is, in fact, free of walnut protein.  That would mean using an assay that is validated for use with the specific product - not just an assay aimed at foods.   If there is no walnut protein, than there is no concern.  The important thing is to document the situation, don't assume anything.