Jump to content

  • Quick Navigation
Photo

Guidance on the new BE labeling requirements


  • You cannot start a new topic
  • Please log in to reply
6 replies to this topic

#1 Jimie74

Jimie74

    Grade - Active

  • IFSQN Active
  • 6 posts
  • 1 thanks
3
Neutral

  • Uruguay
    Uruguay

Posted 02 October 2019 - 03:23 PM

Hello everyone,

 

I have been working in food safety for about five years and following the forums for about that long. I worked in quality assurance / regulatory affairs in medical devices prior to my current position. I did a few quick searches on the forums for guidance on the new BE labeling requirements. The way I understand it, if a supplier tells us that the ingredient we purchase from them is not BE due to refining, etc. and has no genetic material present we do not have to label our product as BE even if that ingredient is from a known BE crop. What evidence should I be asking for from my suppliers to support their claim of no BE? 

 

Thank you in advance for any help!

Jimie



Thanked by 1 Member:

#2 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 17,385 posts
  • 4840 thanks
944
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 02 October 2019 - 08:13 PM

What is BE ?


Kind Regards,

 

Charles.C


#3 pHruit

pHruit

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,389 posts
  • 590 thanks
298
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 03 October 2019 - 08:25 AM

What is BE ?

I believe BE = bioengineered. See e.g. https://www.ams.usda...-regulations/be

 

OP - I'm not that close to US labelling so don't take my word as gospel, but my reading is that your interpretation is correct and the absence of detectable genetic material negates the labelling requirement. Have you checked your product(s) using the USDA's decision tool? If not then try: https://www.ams.usda...ons/be/zingtree

 

The suppliers may be able to provide e.g. PCR results showing no modified DNA is detectable, and/or process details to that demonstrate why this is the case?



Thanked by 1 Member:

#4 Jimie74

Jimie74

    Grade - Active

  • IFSQN Active
  • 6 posts
  • 1 thanks
3
Neutral

  • Uruguay
    Uruguay

Posted 03 October 2019 - 05:32 PM

Yes, BE is bioengineered. I have played around with the USDA decision tool and so far, I like it. If a supplier tells me their item does not contain DNA I would not be out of line to require them to provide me with the process validation and test results proving the absence of DNA? In my previous life in medical devices I rarely had issues getting information from suppliers. It has been my experience so far in food manufacturing that getting information from our suppliers is like pulling teeth. Is that normal, or are our suppliers just being difficult?

 

Thanks!

Jimie



#5 pHruit

pHruit

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,389 posts
  • 590 thanks
298
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 04 October 2019 - 08:11 AM

I was also quite impressed with the decision tool - the EU could learn a thing or two from this ;)

 

Your suppliers are alas not atypical in the food industry. I've never understood it, as the people being chased are fellow QA/technical folk so must also understand the frustration of getting no / indifferent / slow support.

Sometimes it can be a case of asking for something that they haven't done or thought about, and them being somewhat embarrassed about it to the extent they'd prefer to just ignore you and appear inept, rather than admitting it isn't in place and positively advising that they're working on it.

But there do also seem to be a lot of apathetic businesses out there. The silver lining, such as it is, is that when they are your competitors it can be very satisfying stealing sales from them by providing proper support ;)



#6 Jimie74

Jimie74

    Grade - Active

  • IFSQN Active
  • 6 posts
  • 1 thanks
3
Neutral

  • Uruguay
    Uruguay

Posted 04 October 2019 - 11:32 AM

Thank you for the insight. I hadn't considered the suppliers not having the information and not wanting to 'fess up to it. I suppose one of my faults is sometimes I'm too honest. lol I think part of my frustration is too, that in this company I have to request everything from the purchasing manager. She will then contact the suppliers - and I'm sure it goes though another layer at the supplier before getting to an actual QA / tech person. I envision it as being like a game of telephone. My original request is not really getting through to the QA people at the supplier, but rather a slightly modified version. I have requested to cut out these "middle" people and let me talk directly to the QA people at the suppliers. Unfortunately, that was frowned upon and I was told to go through the purchasing manager, despite having very valid arguments as to why that is not an efficient use of resources. Now I am starting to rant! Sorry! Anyway, thank you for the help. 



#7 sbarzee

sbarzee

    Grade - AIFSQN

  • IFSQN Associate
  • 28 posts
  • 2 thanks
1
Neutral

  • United States
    United States

Posted 15 September 2020 - 01:00 AM

As previously mentioned, the USDA has created a tool to help regulated entities who are subject to the National Bioengineered Food Disclosure Standard determine whether they are a regulated entity that must comply with the law. Find the link to the decision tree here:

 https://www.ams.usda...ons/be/zingtree

 

If anyone comes up with a good supplier questionnaire to determine if a supplier's ingredients contain bioengineered foods as per the new National Bioengineered Food Disclosure Standard, please post it here, or edit the one I started below.

 

Here's what I'm thinking based on the USDA's questionnaire (see link above).

 

List of Bioengineered Foods:

Alfalfa

Apple (ArcticTM varieties)

Canola

Corn

Cotton

Eggplant (BARI Bt Begun varieties)

Papaya (ringspot virus resistant varieties)

Pineapple (pink flesh varieties)

Potato

Salmon (AquAdvantage)

Soybean

Squash (summer)

Sugarbeet

 

1. Are any of the ingredients or sub-ingredients that you are supplying on the above list of bioengineered food?

If yes, please answer the following questions.

2. Does the BE ingredient contain detectable modified genetic material? (If no, please provide testing results.)

3. Has the BE ingredient been subjected to a validated refining process that renders modified genetic material undetectable? (If yes, please provide supporting documentation.)

4. Is the BE sub-ingredient present in an amount less than five percent? (If yes, please provide supporting documentation.)






0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate