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Celery as an allergen in an online supermarket


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Ntg

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Posted 23 November 2020 - 09:58 PM

Dear all, we are an online supermarket selling grocery products mainly prepacked but there are also unpacked fruits and vegetables. Between them we have also unpacked celery. Do I need to include it in my hazard analysis? Are there risks of cross contaminating other open vegetables? Do I need to apply specific measures? Thank you



Charles.C

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Posted 24 November 2020 - 02:13 AM

Dear all, we are an online supermarket selling grocery products mainly prepacked but there are also unpacked fruits and vegetables. Between them we have also unpacked celery. Do I need to include it in my hazard analysis? Are there risks of cross contaminating other open vegetables? Do I need to apply specific measures? Thank you

Hi Ntg,

 

Food Standard (if involved) is not mentioned ?

 

Don't know about Greece Food Regulatory requirements but here is example situation in UK -

 

https://www.food.gov...food-businesses

(eg see Non-prepacked [loose] foods)

.


Kind Regards,

 

Charles.C


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Posted 24 November 2020 - 07:24 AM

Hello, thank you for your answer.
For the moment no food standard, building the HACCP... The company will operate in EU.

I have seen your link, but I am not sure if it covers also this case. Have you seen in any British supermarket to have any measure in the vegetables section that they sell celery? I suppose the reason is that cross contamination is difficult.... Any other ideas and recommendations would be more than welcome! Thank you



Charles.C

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Posted 24 November 2020 - 02:32 PM

Hello, thank you for your answer.
For the moment no food standard, building the HACCP... The company will operate in EU.

I have seen your link, but I am not sure if it covers also this case. Have you seen in any British supermarket to have any measure in the vegetables section that they sell celery? I suppose the reason is that cross contamination is difficult.... Any other ideas and recommendations would be more than welcome! Thank you

Hi Ntg,

 

As I understand, this is currently a hypothetical Process to be launched within EU.

 

I suggest you do a Risk assessment  regarding the risk of allergenic (eg celery) cross-contamination for your envisaged process.

 

It is indeed possible that any Regulatory aspect will vary with specific Location so this aspect may depend on yr projected launch.

 

I suggest you try googling something like <<< supermarket risk of celery allergen cross-contamination >>

 

I have attached 2 files which afaik represent/describe the current EU allergen situation in some detail -

 

Attached File  fsa,2020,-food-allergen-labelling-and-information-requirements-technical-guidance_0.pdf   480.37KB   5 downloads

 

Attached File  REGULATION (EU) No 1169 (2011).pdf   1.12MB   3 downloads

 

PS - regret not currently in UK so not familiar with supermarket handling procedures.

 

This Codex (2019) Discussion Group indicates that an allergen  Code of Practice for food business operators is (maybe) currently around Step 5 .

Attached File  Codex, 2019, Discussion Paper on Allergen Labelling.pdf   457.62KB   9 downloads


Edited by Charles.C, 24 November 2020 - 02:45 PM.
added PS

Kind Regards,

 

Charles.C


Ntg

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Posted 24 November 2020 - 07:14 PM

Hi Ntg,

As I understand, this is currently a hypothetical Process to be launched within EU.

I suggest you do a Risk assessment regarding the risk of allergenic (eg celery) cross-contamination for your envisaged process.

It is indeed possible that any Regulatory aspect will vary with specific Location so this aspect may depend on yr projected launch.

I suggest you try googling something like <<< supermarket risk of celery allergen cross-contamination >>

I have attached 2 files which afaik represent/describe the current EU allergen situation in some detail -

fsa,2020,-food-allergen-labelling-and-information-requirements-technical-guidance_0.pdf

REGULATION (EU) No 1169 (2011).pdf

PS - regret not currently in UK so not familiar with supermarket handling procedures.

This Codex (2019) Discussion Group indicates that an allergen Code of Practice for food business operators is (maybe) currently around Step 5 .
Codex, 2019, Discussion Paper on Allergen Labelling.pdf


Thanks a lot for the answer and the links! But still all recommendations or legislations are not answering the question... I have some celery plants next to other uncovered vegetables, is this a risk? I suppose it because otherwise special measures should have been applied during the harvesting of celery with other vegetables. So if nothing done during harvesting, similarly the risk of cross contamination on the vegetables shelf almost zero. It is a different case if celery is an ingredient for a product. In that case of course it has to be declared, but as a row vegetable... Do you agree?


Charles.C

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Posted 24 November 2020 - 11:04 PM

Thanks a lot for the answer and the links! But still all recommendations or legislations are not answering the question... I have some celery plants next to other uncovered vegetables, is this a risk? I suppose it because otherwise special measures should have been applied during the harvesting of celery with other vegetables. So if nothing done during harvesting, similarly the risk of cross contamination on the vegetables shelf almost zero. It is a different case if celery is an ingredient for a product. In that case of course it has to be declared, but as a row vegetable... Do you agree?

^^^(red). Yes it is. Just as an unrelated example, SQF typically require incoming packed ingredients which have different allergens to be isolated from each other in storage. The risk is "potential" (unintentional) allergenic cross-contamination.

From a HACCP POV, the control measures frequently (rightly or wrongly) overlap labelling.

 

The topic of "unintentional contamination"  has generated the widespread, highly debated, commercial usage of "may contain" /  "precautionary labeling" . (eg see section 3.6  in the 3rd attachment of my previous Post + comment in 1st attachment).

 

Allergen Labelling issues can be locationally complex and  particularly involve (a) intentionally/unintentionally added allergens and (b) Prepackaged / non Prepackaged Goods, eg see Pgs 2-12 in this attachment discussing US and UK-EU scenarios (ca. 2017)

Attached File  Evaluating the Risk of Allergen Cross-Contact in Ice-Cream.pdf   1005.16KB   3 downloads


Edited by Charles.C, 25 November 2020 - 12:14 AM.
added/edited

Kind Regards,

 

Charles.C





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