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maylao123

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Posted 05 August 2020 - 05:37 PM

Hi everyone,

 

Our plant contains 4 different types of allergens (soy, wheat, sesame, fish) with their dedicated production lines. If we do change-overs between production of different allergens, we do allergen swab after sanitation for verification of effectiveness.

 

Recently, our management have decided to put "May contain XXXX" allergen precaution statement on the labels of all our products to cover all potential cross-contamination. So that if the operator forget to request allergen swab during change-over, the label still can protect the consumers and company, does it really work like that? if it does, what's the point to do the allergen swab?

 

Please share and help me!! Thanks.



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Posted 05 August 2020 - 05:44 PM

Sounds good doesn't it?

 

No, it just informs the consumer that the food is made in a facility with those items.

 

As a consumer it helps to know these things - however it is not a protection for me nor the company.

 

Is this a regulatory requirement in Canada?


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maylao123

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Posted 05 August 2020 - 05:52 PM

Sounds good doesn't it?

 

No, it just informs the consumer that the food is made in a facility with those items.

 

As a consumer it helps to know these things - however it is not a protection for me nor the company.

 

Is this a regulatory requirement in Canada?

Yes, there is a regulatory requirement from CFIA to claim allergen precautionary statement if there is risk of cross-contamination.



olenazh

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Posted 05 August 2020 - 05:58 PM

Precautionary statement does not eliminate addressing potential risks as it's stated by CFIA "Regulated parties are responsible for the safety of their products, including addressing potential risks associated with the presence of allergens." It's not mandatory to put precautionary statements as they might be misleading.

One of my clients, ice cream manufacturer, has ONLY ONE precautionary statement at the bottom of each label "Product is manufactured at the facility carrying peanuts or their derivatives" - though, potentially the factory has a lot of allergen ingredients (which are stated as ALLERGENS on corresponding labels) Over many years, CFIA never objected this company's labels.



maylao123

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Posted 05 August 2020 - 05:59 PM

Sounds good doesn't it?

 

No, it just informs the consumer that the food is made in a facility with those items.

 

As a consumer it helps to know these things - however it is not a protection for me nor the company.

 

Is this a regulatory requirement in Canada?

Of course, it would relief our pressure to monitor the allergen swabbing, but does it really work like this?? I don't want the operators just think the labels are their guard and they don't need to follow the procedure.



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Posted 05 August 2020 - 06:09 PM

Of course, it would relief our pressure to monitor the allergen swabbing, but does it really work like this?? I don't want the operators just think the labels are their guard and they don't need to follow the procedure.

 

 

No, it doesn't work like that.  This is an area of major responsibility - there is no relief of pressure here. The real pressure would come the day an allergen incident occurs and your company hurts people.


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Glenn Oster
 
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maylao123

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Posted 05 August 2020 - 06:12 PM

Precautionary statement does not eliminate addressing potential risks as it's stated by CFIA "Regulated parties are responsible for the safety of their products, including addressing potential risks associated with the presence of allergens." It's not mandatory to put precautionary statements as they might be misleading.

One of my clients, ice cream manufacturer, has ONLY ONE precautionary statement at the bottom of each label "Product is manufactured at the facility carrying peanuts or their derivatives" - though, potentially the factory has a lot of allergen ingredients (which are stated as ALLERGENS on corresponding labels) Over many years, CFIA never objected this company's labels.

Thanks for sharing. Our precautionary statement covers all the allergens in our plants, I understand that it can protect the consumer and to some extent relief the pressure of QA and operators. But I don't know whether it works if operator keep forgetting to request the swab since they think the labels would cover the risk.  



olenazh

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Posted 05 August 2020 - 06:19 PM

I don't think, MAY CONTAIN statement would protect the consumer, it'd just add confusion as consumers're not that educated (excluding such knowledgeable people like Glenn:)) and would not differentiate "contain" from "may contain" So, it could be risky for your company in terms of losing potential customers refusing to buy your products due to allergens...



The Food Scientist

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Posted 05 August 2020 - 09:40 PM

In a perfect world where a facility would be 10000000% trained and competent in their allergen program, they would not need to put that may contain... so I believe that facility doesn't exist.. (maybe it does). 

 

Not really knowledgeable about regulation in Canada but you Instead of may contain put a manufacturing statement like for example "This product is packed in a facility where (list all allergens) are processed".  That case protecting the consumer without confusing them with the may contain.


Edited by The Food Scientist, 05 August 2020 - 09:43 PM.

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