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Is the "may contain" statement required by SQF?


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#1 sjohnson

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Posted 15 October 2018 - 08:20 PM

Hello,

Does anyone know if the "may contain" statement is required by SQF? I have done some research and it only seems per the FDA it is Not required to have this statement. We currently have a "may contain peanuts and treenuts" however we are considering processing soy, dairy and wheat in our facility.  I appreciate any input on this topic.



#2 MsMars

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Posted 15 October 2018 - 09:00 PM

Have you done any allergen swabbing on your "May Contain" product equipment? Do you have a reasonable risk of contamination or is this simply a customer requirement? That particular statement is not required specifically by SQF to my knowledge, just that you follow applicable regulatory labeling requirements.  I've always thought "May Contain" statements are more of a CYA inclusion on labeling; if there were a reasonable risk of contamination, you'd need to label it on your "Contains" statements. 



#3 MsMars

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Posted 15 October 2018 - 09:02 PM

We are considering processing soy, dairy and wheat in our facility.  I appreciate any input on this topic.

 

An addition: I would consider placing a "Processed in a facility that also processes...." statement in this case. 



#4 sjohnson

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Posted 15 October 2018 - 09:34 PM

Thank you yes either a may contain... or processed in.. statement is what I'm asking about.  We currently have separate machines and processing areas for these allergens but considering sharing equipment. In that case we were searching for if it is required by Any certifying body to have the statement on the packaging listing all the allergens ran on the shared machines. I believe ethically yes, however I need a firm must if that is the case to present to the higher ups.



#5 Charles.C

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Posted 16 October 2018 - 03:36 AM

Hi sjohnson,

 

"May contain" is nowadays typically a manufacturing fudge for legal self-protection.

 

FDA afaik consider that it's use must be accompanied by a satisfactorily rigorous allergen control program to minimise risk of any related hazards.

 

The FARRP website has a detailed presentation of the practical/ethical aspects of using such terminologies.


Kind Regards,

 

Charles.C


#6 Scampi

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Posted 16 October 2018 - 12:37 PM

I agree with Charles...............you shouldn't be trying to meet the GFSI standard on labeling issues............this is a legal issue and as such you are governed by the laws of the land NOT SQF


Because we always have is never an appropriate response!


#7 MsMars

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Posted 16 October 2018 - 01:01 PM

Be prepared to implement a robust sanitation and swabbing program as part of your Sanitation/Allergen Controls if you plan on using the same equipment to process both.  Even with that, definitely would still include the statement if it were my facility. As Scampi stated - this is a regulatory issue first, so that should help your case with your "higher-ups." 






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