4 replies to this topic

[Joelle]

Hello I have a question about the manufacturing of product with allergens in a production plant.

 

1. If a plant produce different products but some of the products contains allergens, considering that the product with allergen is produce with dedicated equipment/instruments and in a dedicated room, is it mandatory to write on the label of all product may contain allergen?

 

2. If an equipment can be used for a product with no allergen and also a product with allergen but the equipment is properly cleaned with a validated method. Is is mandatory to indicate of the label of the product that is not containing allergen "may contain Allergen".

 

3.  Can we produce in the same room but on dedicated equipment a product that contains allergen and another product that does not contain allergens or it should be in two different room?

 

Thank you.

Joëlle

 

 

 

[Jpainter]

Joelle, 

 

Much of this depends on your setup and risk assessment. For example, in what form are your allergenic ingredients, if it is a powdered ingredient it may become aerosolized and settle on non-allergen equipment. In my previous job, we ran allergen and non allergen products in the same production room on different lines. To accomplish this, we color coded outer garments, gloves and hairnets of workers to differentiate, and also labeled all equipment producing allergenic products. Again, labeling depends on your risk assessment. if you are 100% certain all allergenic proteins are removed you may not need a statement. If you are not 100% certain you may want to include a statement along the lines of "produced on shared equipment with products containing insert allergen(s)"

[Joelle]

In your previous job, did you labeled the non allergen products (that was produce in the same product room than the allergen product)  "may contain allergen" or not?

Thank you for your help. Joëlle

[Jpainter]

We did not. That being said, we had an extensive allergen control program with employee segregation, lots of rapid allergen tests, labeling of equipment and ingredients, and an allergen color coding program among other policies. 

[mgourley]

Hello I have a question about the manufacturing of product with allergens in a production plant.

 

1. If a plant produce different products but some of the products contains allergens, considering that the product with allergen is produce with dedicated equipment/instruments and in a dedicated room, is it mandatory to write on the label of all product may contain allergen?

 

If I understand you correctly, you are producing a product that contains allergens, is produced in a dedicated space with dedicated equipment. Do you have to label the product with the allergens it contains? Yes, absolutely.

 

2. If an equipment can be used for a product with no allergen and also a product with allergen but the equipment is properly cleaned with a validated method. Is is mandatory to indicate of the label of the product that is not containing allergen "may contain Allergen".

 

"may contain" statements are allowed (in the US at least). But it does not absolve you of legal ramifications if a consumer issue happened where there was indeed an allergic reaction to a product.
However, if your production equipment is cleaned as you say, there should not be a problem labeling it with no allergens. 

 

3.  Can we produce in the same room but on dedicated equipment a product that contains allergen and another product that does not contain allergens or it should be in two different room?

 

It all depends on your allergen management system and the construction of your "room". Ideally, it should be in two different rooms.

We have three cookie lines in one space. We produce different varieties of cookies with different allergens or gluten free at the same time.

​Because of the layout of the space, there is sufficient room between the lines to prevent anything other than deliberate allergen cross contact.

 

It would be helpful to know what kind of product(s) you produce and what allergens you have.

 

Marshall