6 replies to this topic

[EWNB Sanitation]

Specifically, I am wondering about where I may find all relevant FSMA text on allergen control and labeling.

 

Our factory produces tahini (made of sesame) as well as almond and cashew butter (major allergens) on the same production line.

 

We label the tahini as made "in the same production line as...", and no one has ever called with a problem, presumably because no one with a major allergy would touch our product knowing the warning.

 

We deeply clean all of our production equipment before using it for tahini production, and in between the sanitation and production, we take swabs and send them to a laboratory for allergen testing. Is this practice just icing on the cake? Is there a reason I should keep doing this when no customer asks? Is it required by FSMA in any way?

 

Thank you for your guidance!

 

Warren

[Dr.Khan]

Hi Warren

 

What you are doing is good enough to ,avoid  cross contamination of products produced on the same line.Yes i is the requirement of FSMA  that production line should be clean prior to producing allergen containing products and at the end of the production.

 

Kind regards

Dr Humaid khan 

Managing Director

Halal International Services

Australia 

[FoodSafetyPlanet]

Hi Warren, 

 

Right off the bat, ensure the actual allergen is labeled in the "contains" statement, start using a rapid detection allergen swab, and modify your production schedule to minimize cross-contact. 

 

An allergen control program can support you more than the generic label. 

 

Resource, resource

[The Food Scientist]

You can have a rapid few seconds test for allergens to verify sanitation instead of sending them out. To validate, you can do the testing of products and send outside. You can do that twice annually. Since you use shared equipment have more than one allergen, then yes you shall go through all procedures to prevent allergen cross contamination. I had a dept. of agriculture inspector visit us last week and she was interested in the allergen program. 

Edited by The Food Scientist, 09 September 2019 - 04:09 PM.

[larissaj]

I agree with getting a quick allergen swabs, you get the results within 5 minutes (some swabs are faster) and it will tell you if you have any residue on there. Also, as long as you always run the non allergen first you should also be set. 

[EWNB Sanitation]

Thanks, everyone. I appreciate you folks and IFSQN.

[Charles.C]

Specifically, I am wondering about where I may find all relevant FSMA text on allergen control and labeling.

 

Our factory produces tahini (made of sesame) as well as almond and cashew butter (major allergens) on the same production line.

 

We label the tahini as made "in the same production line as...", and no one has ever called with a problem, presumably because no one with a major allergy would touch our product knowing the warning.

 

We deeply clean all of our production equipment before using it for tahini production, and in between the sanitation and production, we take swabs and send them to a laboratory for allergen testing. Is this practice just icing on the cake? Is there a reason I should keep doing this when no customer asks? Is it required by FSMA in any way?

 

Thank you for your guidance!

 

Warren

 

Hi Warren,

 

Yr post sadly illustrates the safety communication difficulties which bedevil the allergen labelling issue.

 

Allergenicity can result in a  potentially fatal event  if  relevant cross-contaminants are ingested by a vulnerable consumer.

 

If USDA were controlling yr product (I assume they do not?)  you would presumably also have to label sesame as an (ingredient) allergen.