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Allergen Alibi and Risk Assessment


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#1 Dalways

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Posted 18 March 2020 - 08:30 AM

Hi All 

In the amidst of COVID-19,  I got a general query on good old allergen labeling . 

 

We as a manufacturer do not handle or store peanut on site but we handle all different tree nuts sourced from all around the world from different supplier. As Nut supplier most of our nut supplier do not handle peanut either on site as they are dedicated one or few kind of tree nuts only but few European supplier handle Peanut and take an advisory statement as packed in same site which handles Peanut and some take allergen alibi too as they are packed in the same line. 

 

all these time as we dont handle peanut on site we never took may contain claim on any of our finished product ( We make chocolate and various cocoa confectioneries). One of our retail client by default take Allergen Alibi for peanut as their own corporate policy considering that most nut supplier handles peanuts but rest of our client dont take that advisory claim for peanut as we dont handle them or store peanut on site. 

 

Under my site allergen risk assessment too which is a very comprehensive one it doesn't ask me to take the peanut as alibi either. We do got an annual validation process too. 

 

So now the query is " we are developing a new product which is a chocolate coated biscuit ,a type of very specialized biscuit limiting to couple of suppliers in Europe only  and they take Peanut as may contains statement. After having a discussion and reviewing their allergen risk assessment they ruled out the sesame and egg allergen we found they were quite over declared ! and the same process and steps and equipment used same as peanut but they said though we understand sesame and egg risk is low we will never avoid peanut alibi as an allergen . I really didn't get it as i can see the risk factor is over estimated. Now we want to use the biscuit and will take Peanut as allergen may contain on final pack label but as its a biscuit which is already made in solid form I am interested to know the thought of the forum to advise how much does it affect exiting line allergen advisory and may contain statement. 

 

I can always make a positive release by checking the raw material for peanut allergen and i will do that in this case to protect due diligence defense if necessary for future but should it be affecting my any existing product if this biscuit is introduced to my site which is taking an overkill as may contain peanut statement :)

 

Please advise 

 

Regards 

Deb



#2 Tobiasman

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Posted 18 March 2020 - 10:13 AM

Dear Deb

 

I would say that if your suppliers do not seem confident enough to rule out the peanut allergen, you are right in using the "may contain peanut"  in your product.

In the same line of thought, and even know I understand it could be an overkill, if there is this risk from your suppliers, you would need to either extend the "may contain peanut" statement to the remaining products produced in the same line or have a very well validated cleaning procedure that removes the risk of cross-contamination by this allergen. 

 

I understand your point about this being an "overkill", but if your suppliers are not confident enough, there should be a reason for this, and if any problems arise I don't see how you can be covered... What if they choose their systems and the risk of peanut cross contamination increases? Will they inform you, or would they consider you are already aware of this potential cross-contamination, as they already informed ou of this?

 

Regards

Ricardo Kaku 



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#3 Charles.C

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Posted 18 March 2020 - 11:44 AM

Hi All 

In the amidst of COVID-19,  I got a general query on good old allergen labeling . 

 

We as a manufacturer do not handle or store peanut on site but we handle all different tree nuts sourced from all around the world from different supplier. As Nut supplier most of our nut supplier do not handle peanut either on site as they are dedicated one or few kind of tree nuts only but few European supplier handle Peanut and take an advisory statement as packed in same site which handles Peanut and some take allergen alibi too as they are packed in the same line. 

 

all these time as we dont handle peanut on site we never took may contain claim on any of our finished product ( We make chocolate and various cocoa confectioneries). One of our retail client by default take Allergen Alibi for peanut as their own corporate policy considering that most nut supplier handles peanuts but rest of our client dont take that advisory claim for peanut as we dont handle them or store peanut on site. 

 

Under my site allergen risk assessment too which is a very comprehensive one it doesn't ask me to take the peanut as alibi either. We do got an annual validation process too. 

 

So now the query is " we are developing a new product which is a chocolate coated biscuit ,a type of very specialized biscuit limiting to couple of suppliers in Europe only  and they take Peanut as may contains statement. After having a discussion and reviewing their allergen risk assessment they ruled out the sesame and egg allergen we found they were quite over declared ! and the same process and steps and equipment used same as peanut but they said though we understand sesame and egg risk is low we will never avoid peanut alibi as an allergen . I really didn't get it as i can see the risk factor is over estimated. Now we want to use the biscuit and will take Peanut as allergen may contain on final pack label but as its a biscuit which is already made in solid form I am interested to know the thought of the forum to advise how much does it affect exiting line allergen advisory and may contain statement. 

 

I can always make a positive release by checking the raw material for peanut allergen and i will do that in this case to protect due diligence defense if necessary for future but should it be affecting my any existing product if this biscuit is introduced to my site which is taking an overkill as may contain peanut statement :)

 

Please advise 

 

Regards 

Deb

 

Hi Deb,

 

I assume "Allergen Alibi" is UK slang. I assume = ^^^ (blue)..

 

^^^(red) Sorry for my ignorance but I found this portion of  text incomprehensible.


Kind Regards,

 

Charles.C


#4 Dalways

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Posted 18 March 2020 - 12:17 PM

Hi Ricardo / Charles 

thank you for your comment. yes I will take may contain peanut on the finished product for this line but i was more curious to understand will it make any difference to our other existing lines as currently they dont take may contain peanut  statement but will be made in the same line. to note all our product packaging are already made and printed its a difficult decision to introduce this new allergen may contain for a raw material 

 

" YES: the allergen alibi is UK used term started by one retailer and kind of got used as a jargon for may contain statement :)

 

Reagrds

Deb 



#5 pHruit

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Posted 18 March 2020 - 12:45 PM

Was the bit that Charles highlighted in red about your review of your raw materials suppliers' allergen risk assessments?

i.e. are they saying that they genuinely are unable to control potential cross-contamination from this allergen and have confirmed as much via risk assessment?

 

If there is material that potentially contains peanut entering your site and this is a legitimate risk that the suppliers can't eradicate then your next step is perhaps to review your own risk assessment, which may need to be updated anyway if a new allergen is (possibly...) being introduced to the facility?

 

That would then fully inform your decision, perhaps in conjunction with a review of the FSA's Technical Guidance on Allergen Labelling (https://www.food.gov...al-guidance.pdf), the Chartered Institute of Environmental Health's white paper on improving "may contain" labelling (https://www.cieh.org...-statements.pdf), the BRC/FDF guidance on allergen labelling (http://www.reading.a...n-Labelling.pdf) and similar.






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