Allergen Free/Gluten Free facility question

We are an allergen free and gluten free facility.  We are a RTD beverage manufacturer.

During our production process, we generate a lot of scrap corrugated cardboard that we recycle.

We receive used empty cardboard totes that we use as scrap bins for the cardboard.

I noticed that one of the empty cardboard totes has an Allergen tag on it.  It is empty, but previously contained an allergen.

Can this become an issue?  It is a violation of our allergen free claim? 

Your thoughts are welcome.

Thank you.

Leo

We are an allergen free and gluten free facility.  We are a RTD beverage manufacturer.

 

During our production process, we generate a lot of scrap corrugated cardboard that we recycle.

 

We receive used empty cardboard totes that we use as scrap bins for the cardboard.

 

I noticed that one of the empty cardboard totes has an Allergen tag on it.  It is empty, but previously contained an allergen.

 

Can this become an issue?  It is a violation of our allergen free claim? 

 

Your thoughts are welcome.

 

Thank you.

 

Leo

Most important for an allergen free facility to check EVERYTHING coming in - before it actually comes in.

I have two clients that run allergen free facilities - they would be freaking out in this situation as NOTHING comes in that has the potential (even remote) contaminate.  ALL totes need to get checked and since you have noticed one with an allergen sticker on it I imagine there are others from the same source that may be missing stickers, etc.

My clients don't use "used" totes - all use new.

Both also, check loads and trailers with fast testers prior to the truck backing up to the docks.

I'd be gettng all the totes out and running testing right now.

We are an allergen free and gluten free facility.  We are a RTD beverage manufacturer.

 

During our production process, we generate a lot of scrap corrugated cardboard that we recycle.

 

We receive used empty cardboard totes that we use as scrap bins for the cardboard.

 

I noticed that one of the empty cardboard totes has an Allergen tag on it.  It is empty, but previously contained an allergen.

 

Can this become an issue?  It is a violation of our allergen free claim? 

 

Your thoughts are welcome.

 

Thank you.

 

Leo

Looks like it might be time for you to change your cardboard tote procedure. I personally would not allow "used" cardboard totes to be brought in to my facility. The risk here outweighs any cost benefits...especially if you now have to do allergen testing/swabbing of areas where this tote has traveled (which it sounds like you do).

On the other hand, how many used totes could you have received that potentially contained an allergen (or other contaminant) that wasn't tagged on the tote? 

I had a similar issue in my company. We manufacture gluten-free and egg and lactose free products, and some samples were contaminated by lactose coming from a cardbox.

Luckily we solved it quickly but I recommend you to ask every supplier about the allergen management program they have.

Sometimes they send you an allergen-free statement and they don't control a possible contamination during transportation.

The more I ask my suppliers the more gaps I find in their allergen management program.