Hi all,
Just last week our company got into a bit of a mess with FSIS while running a meat product and I am curious what your thoughts are. We make RTE meat frozen entrees with some slight variations in the formulations of each one. Last week we used our extruder pump to fill ravioli with an egg, wheat, and milk allergen filling. This filling also contains ricotta cheese which is important. At the conclusion we flushed as much of the filling as possible through the pump. Next we loaded up the pump with a meat filling containing an identical allergen profile but it does not contain ricotta cheese. The amount of the first "cheese" filling left over being incidentally pumped into the meat filling is minimal; maybe 1% for the first 20 seconds and then trace amounts after that. At the conclusion of the the collective ravioli run our FSIS inspector noticed that the entire line was not fully washed down to prevent the trace amount of cheese filling being pumped into the meat ravioli. He then proceeded to tag all of our product which was run after the changeover until it could be re-labelled to include the ricotta cheese (misbranding). Obviously if there was any allergen concern this would be a red alarm situation however there is no concern on that front. Our inspector is essentially raising any and every raw material to the level of an allergen in terms of risk by claiming misbranding. I have been looking for a regulatory provision that would allow trace amounts of ingredients to be transferred without claiming misbranding but am coming up short. I know there are exceptions for things like processing aides but I don't think left over ricotta cheese would be included in that.
Any ideas would be really helpful because our company has been doing it this was for decades and having to do a full wash down of cooker, freezers, pump, conveyers, etc. would significantly reduce our ability to make product. Thanks!