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#1 SpiceyQA

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Posted 30 October 2019 - 02:26 PM

Quick question y'all:

 When one of my ingredients has a "may contain: XXXX" on their  label, do I have to use that on my label as well?



#2 Njaquino

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Posted 30 October 2019 - 04:20 PM

I do not because I do random sampling in which I include allergens. You can ask for a letter of guarantee. When in doubt asses the risk. 

 

I typically only add "may contain" statement if I run allergens on the same line or in the facility. Remember "may contain" statement does not legally protect you, we still need to have an allergen management plan to validate no cross contamination is happening.



#3 pHruit

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Posted 30 October 2019 - 04:24 PM

My recollection is that the FALCPA doesn't include any formal requirement / provision for "may contain" type labels: https://www.fda.gov/...rgens-edition-4

 

Given the understandable position that "may contain" shouldn't be used as an alternative to good manufacturing practice and proper control, in your position I'd first want to understand the basis of the supplier's position on this.
If there is a genuine possibility of allergen presence that they cannot reasonably address, and that possibility therefore extends to the products in which you are using the ingredient, then I you will need to consider using the same statement. Or possibly finding an alternative source?

 

 

I do not because I do random sampling in which I include allergens. You can ask for a letter of guarantee. When in doubt asses the risk. 

 

I typically only add "may contain" statement if I run allergens on the same line or in the facility. Remember "may contain" statement does not legally protect you, we still need to have an allergen management plan to validate no cross contamination is happening.

 

The OP's situation isn't under their direct control; the potential contamination is happening at a supplier's site. I'd be a bit wary of random sampling as a verification activity in this type of situation - "may contain" (hopefully) implies a low probability of actual contamination, so the question is: if the allergen is present at a low level, what is the actual likelihood of this being detected rather than missed by a sampling exercise?



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#4 SpiceyQA

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Posted 30 October 2019 - 07:10 PM

My recollection is that the FALCPA doesn't include any formal requirement / provision for "may contain" type labels: https://www.fda.gov/...rgens-edition-4

 

Given the understandable position that "may contain" shouldn't be used as an alternative to good manufacturing practice and proper control, in your position I'd first want to understand the basis of the supplier's position on this.
If there is a genuine possibility of allergen presence that they cannot reasonably address, and that possibility therefore extends to the products in which you are using the ingredient, then I you will need to consider using the same statement. Or possibly finding an alternative source?

 

 

 

The OP's situation isn't under their direct control; the potential contamination is happening at a supplier's site. I'd be a bit wary of random sampling as a verification activity in this type of situation - "may contain" (hopefully) implies a low probability of actual contamination, so the question is: if the allergen is present at a low level, what is the actual likelihood of this being detected rather than missed by a sampling exercise?

Right we have a tool for verifying the lack of allergens after each run of an allergen containing product and I am confident in it's efficacy. However this is a Chinese import and , not to be improper, but we know the current reputation of food products from that country have had quality problems before. 







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