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If we have an Allergen Management Program in place do we need a may contain statement on labels?


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sharma

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Posted 18 May 2021 - 03:56 PM

Absolutely, because you need to be able to prove that other allergens besides the named allergen aren't making their way into your product.

Hi there, we have an allergen management program in place. We are trying our best to segregate the allergens and validate the cleaning procedures but we have all allergens on site. We  bake cookies, loaf cakes and fruit cake and donuts as an e.g. milk , soya, egg, wheat gluten are present is majority products. We took Peanut as a chief allergen as it is not present in all products. We baked Choco chip cookies in morning followed by Peanut butter cookies later in day and loaf cake at same time on the different line here eggs are present in chocolate chip cookies and loaf cakes but not in Peanut butter cookies. We have validated cleaning procedures in place still we write "May Contain eggs" statement on the label for Peanut Butter Cookies. So now here do I need to provide any other clarification? If we are missing something at some point. Thanks in advance 


Edited by Jacob Timperley, 18 May 2021 - 10:38 PM.
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Charles.C

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Posted 18 May 2021 - 04:31 PM

hi there 

we have an allergen management program in place. We are trying our best to segregate the allergens and validate the cleaning procedures but we have all allergens on site. we  bake cookies, loaf cakes and fruit cake and donuts 

as an e.g. milk , soya, egg, wheat gluten are present is majority products .

we took Peanut as a chief allergen as it is not present in all products.

we baked Choco chip cookies in morning followed by Peanut butter cookies later in day and loaf cake at same time on the different line 

here eggs are present in chocolate chip cookies and loaf cakes but not in Peanut butter cookies 

We have validated cleaning procedures in place still we write "May Contain eggs" statement on the label for Peanut Butter Cookies.

so now here do i need to provide any other clarification? 

if we are missing something at some point.

Thanks in advance 

 

Hi sharma,

 

I'm unclear as to what yr specific query is ?


Kind Regards,

 

Charles.C


sharma

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Posted 18 May 2021 - 04:46 PM

Hi sharma,

 

I'm unclear as to what yr specific query is ?

hi Charles 

here i want to ask that if even after having allergen management Program in place and implementation and validated cleaning procedure in place, we mention "may contain statement" .

Is this "MAY CONTAIN" Statement is contradictory? 



Charles.C

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Posted 18 May 2021 - 04:55 PM

hi Charles 

here i want to ask that if even after having allergen management Program in place and implementation and validated cleaning procedure in place, we mention "may contain statement" .

Is this "MAY CONTAIN" Statement is contradictory? 

Hi sharma,

 

Don't know about Canada (added-see Post 7) but it's apparently a routine labelling exercise in many locations, eg USA, and often includes  every remotely possible production cross-contamination.

 

The Idea (rightly or wrongly) is to legally forestall any subsequent customer claims.

 

Commonly known as "Precautionary Labelling".


Edited by Charles.C, 19 May 2021 - 05:47 AM.
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Kind Regards,

 

Charles.C


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Posted 18 May 2021 - 07:57 PM

If I understand your ?? correctly you are asking that since you have allergen plan is that ok in place of putting allergen warning on your label - answer: NO


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Posted 18 May 2021 - 08:05 PM

FYI...."May contains" statements do not preclude manufacturers of having an effective allergen control program.  As such, it really does nothing for you.  It is a false idea that somehow became quite popular for companies to add to their labels.

 

I've been told by a few legal experts in food labeling a "May contains" affords no protections from liability.



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Posted 19 May 2021 - 05:41 AM

FYI...."May contains" statements do not preclude manufacturers of having an effective allergen control program.  As such, it really does nothing for you.  It is a false idea that somehow became quite popular for companies to add to their labels.

 

I've been told by a few legal experts in food labeling a "May contains" affords no protections from liability.

 

Hi Ryan,

 

In truth, it's a problematic situation from a consumer's POV, eg -

 

Attached File  May Contain AllergenStatements, Facillitating or Frustrating Consumers.pdf   987.09KB   16 downloads

 

@sharma - this is apparently Canada's POV (I interpret sort of "pro" rather than "con") -

 

https://www.canada.c...aged-foods.html


Edited by Charles.C, 19 May 2021 - 05:51 AM.
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Kind Regards,

 

Charles.C


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sharma

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Posted 19 May 2021 - 10:24 AM

Thanks Charles,

i will look into this. We are implementing SQF Standards at our site. This part is really challenging, at this moment it seems pretty impossible to remove each and every allergen from the facility. trying best to achieve the standards and get rid of this "May Contain " Statement. But as per CFIA Website this statement is OK to be used as they say about- 

Precautionary Statement 

As part of the development of new policies and regulations for food allergen labelling, Health Canada and the Canadian Food Inspection Agency are undertaking a public consultation. The goal is to update Health Canada's policy and guidelines on precautionary labelling so that they continue to contribute to achieving Health Canada's overall objectives:

  • to minimize risks associated with inadvertent consumption of undeclared food allergens and added sulphites in food; and
  • to maximize choice of safe and nutritious foods for consumers with dietary restrictions.

Combining these goals poses a challenge since precautionary labelling is essential when the possible presence of allergens in food due to cross contact is real and unavoidable, but at the same time, overuse of these statements can unnecessarily limit choices for those with food allergies.

The overall objective of this consultation is to seek feedback from a wide range of stakeholders, and engage them in discussion of the identified issues and proposed actions that could improve the current approach to advising allergic individuals of the possible inadvertent presence of priority allergens in pre-packaged foods sold in Canada. 

 

Looking Forward to new Goals to achieve and provide the best quality.

Thank You Everyone.



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Posted 19 May 2021 - 12:16 PM

Thanks Charles,

i will look into this. We are implementing SQF Standards at our site. This part is really challenging, at this moment it seems pretty impossible to remove each and every allergen from the facility. trying best to achieve the standards and get rid of this "May Contain " Statement. But as per CFIA Website this statement is OK to be used as they say about- 

 

 

I would be curious as to the legality of a "may contains" statement in Canada.  From a USA point of view there is no absolving of liability with a "may contains" statement.

 

Additionally, I'm curious as to your statement of "allergen from the facility" when having an allergen in the facility does not mean it will make cross contact.  Did you mean in the production line or equipment?  If so, yes, that can be difficult, but not impossible.



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Posted 19 May 2021 - 12:19 PM

Hi Ryan,

 

In truth, it's a problematic situation from a consumer's POV, eg -

 

attachicon.gif May Contain AllergenStatements, Facillitating or Frustrating Consumers.pdf

 

@sharma - this is apparently Canada's POV (I interpret sort of "pro" rather than "con") -

 

https://www.canada.c...aged-foods.html

 

Very problematic for consumers which is one reason I hate them.  The other reason is they don't afford any protection for the manufacturer to be honest, at least in the USA.  In that link with the Canadian POV this is stated...

 

Health Canada's policy has been non-prescriptive with respect to the wording of precautionary statements, requiring only that such statements be truthful, clear and non-ambiguous, and that they not be a substitute for Good Manufacturing Practices.

 

 

So...if food manufacturers are following GMP's around allergen control and preventing allergen cross contact why would a precautionary statement come into play?  I can only think of two scenarios, a supplier issue where they have consistent intermixing of allergens for whatever reason, or an equipment cleaning issue that makes it nearly impossible to remove all traces of allergen residues.

 

Are there other scenarios?


Edited by Ryan M., 19 May 2021 - 12:20 PM.


sharma

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Posted 19 May 2021 - 02:27 PM

HI Ryan 

u got it. My main issue is cleaning of equipment.

same equipment use. For different Cookies we use two different machines. I try to schedule all the products according to allergen profile. and Mixers used at same time. may be at two different lines we are baking two different articles using different mixing bowls and paddles but using the mixers at same time. In this condition what we can do? 

cleaning equipment is designated according to allergen profile, great  cleaning products great cleaning efforts but still finding allergens on equipment.

it is a real challenge.

any suggestions?

Thanks in advance

Very problematic for consumers which is one reason I hate them.  The other reason is they don't afford any protection for the manufacturer to be honest, at least in the USA.  In that link with the Canadian POV this is stated...

 

 

So...if food manufacturers are following GMP's around allergen control and preventing allergen cross contact why would a precautionary statement come into play?  I can only think of two scenarios, a supplier issue where they have consistent intermixing of allergens for whatever reason, or an equipment cleaning issue that makes it nearly impossible to remove all traces of allergen residues.

 

Are there other scenarios?



Ryan M.

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Posted 19 May 2021 - 03:47 PM

That's tough because that equipment isn't really designed for easy cleaning.  They will usually require you taking it apart more than normal to get every crack and crevice.

 

The question really is where is the allergen residue coming from after you have cleaned?  If it is on an easy cleanable surface then that means the cleaning procedures are inadequate or inconsistent.  If it is coming from a crevice or hard to clean area then you have to look at how the equipment can be disassembled to get into that area for proper cleaning.

 

One thing allergen programs do is help you find where your equipment is hard to clean and potential related hot spots for bacteria and biofilms.  

 

I don't know if you have the resources, but I would involve your chemical supply representative to help you and you will need maintenance as well because they are the ones who can assist more on the equipment side and disassembly needed.

 

Once you find where your allergen residues remain, or are difficult to remove, then you can put an action plan together to remove them.  If equipment needs further disassembly and that takes additional time and resources you may opt to run allergens, or different allergens, to a set schedule at the end or beginning of the week where you can provide more downtime for the necessary disassembly and cleanup afterwards.

 

If you can tackle this you will also help your microbiological and shelf-life on the products.

 

 

HI Ryan 

u got it. My main issue is cleaning of equipment.

same equipment use. For different Cookies we use two different machines. I try to schedule all the products according to allergen profile. and Mixers used at same time. may be at two different lines we are baking two different articles using different mixing bowls and paddles but using the mixers at same time. In this condition what we can do? 

cleaning equipment is designated according to allergen profile, great  cleaning products great cleaning efforts but still finding allergens on equipment.

it is a real challenge.

any suggestions?

Thanks in advance



Charles.C

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Posted 19 May 2021 - 07:10 PM

Very problematic for consumers which is one reason I hate them.  The other reason is they don't afford any protection for the manufacturer to be honest, at least in the USA.  In that link with the Canadian POV this is stated...

 

 

So...if food manufacturers are following GMP's around allergen control and preventing allergen cross contact why would a precautionary statement come into play?  I can only think of two scenarios, a supplier issue where they have consistent intermixing of allergens for whatever reason, or an equipment cleaning issue that makes it nearly impossible to remove all traces of allergen residues.

 

Are there other scenarios?

 

Hi Ryan,

 

From attachment/Post7 -

 

There are currently four scenarios of using PAL:-

Scenario 1: PAL-labelled food products that have a genuine risk of causing allergic reactions
Scenario 2: Products where there is no serious allergenic risk involved, but manufacturers may feel obliged to ensure that labels carry the warning to cover even the potential of a minor risk
Scenario 3: Products that would not carry PAL because there is no risk of allergenic contamination, but there is concern that consumers would be confused when they cannot find PAL on a product, so as a result, it is included.
Scenario 4: Products where manufacturers are actually unaware of the actual need for PAL
 

(Scenario 3 sounds highly improbable to me)

 

FARRP's comments are also quite interesting -

 

Precautionary labelling

This is the type of labelling that uses terms such as 'may contain'. This type of labelling (also termed advisory labelling or defensive labelling) is strictly voluntary and not required by federal regulation. Consequently, situations when precautionary labelling may be used vary among food companies, as does the wording of the statements used (see Table for some examples but note this list is not exhaustive!!). FDA specifies that such labelling cannot be used as a substitute for good manufacturing practices such as allergen identification and control, cleaning of shared equipment, and segregation during processing.

 

Some consumers believe manufacturers use precautionary labels as a way to protect themselves from legal action in case a food causes a reaction. This is not typically the case since this type of label should only be used by food manufacturers when there actually is a possibility (however small) that the food may contain an allergen which is not an ingredient but may be present as a result of the manufacturing process.

 

We know this type of labelling is not liked by consumers but currently it is the only way for food manufacturers to inform consumers if there is a possibility that an allergen which is not part of the final product may be present in the food. In the future, some restrictions may be placed on the use of precautionary labels but that is not yet the case.

 

From the above table detailing different examples of precautionary labels, it can be seen how manufacturers choose to word their precautionary statements can vary greatly. Consumers MUST NOT interpret this difference in wording as a difference in the likelihood that the stated allergen is present. All precautionary labels mean the same thing, regardless of the words they use. They all mean that there is a possibility that an allergen which is not part of the final product may be present. Consequently all precautionary labels must be treated with the same level of care, regardless of their wording.

 

https://farrp.unl.ed...lergic-consumer

 

IIRC some texts offer Risk Assessment procedures to determine whether "to PAL or Not to PAL"

 

PS - Also ex FARRP -
 

7. What is precautionary allergen labeling?
Precautionary  allergen  labeling  (sometimes  also referred to as allergen advisory labeling) is a voluntary warning to consumers (e.g. may contain milk) added after  the  ingredient  list.  Its  goal  is  to  indicate  a product not intended to contain a specific allergen(s)
may  sporadically  contain  that  allergen  due  to unintentional and unavoidable cross-contact in the manufacturing process even after implementing a comprehensive Allergen Control Plan.

8. I don’t have designated equipment for allergen containing products. Should I use precautionary allergen labeling?
Studies show that a high frequency of precautionary labeling  may result in an increased likelihood that allergic  consumers  will  ignore  these  statements, potentially  putting  them  at  risk  for  an  allergic reaction.  To  protect  consumers,  precautionary allergen  labeling  should  only  be  used  when  it  is concluded  that  sporadic  cross  contamination  of  a product can not be avoided.  This decision should be based  on  a  thorough  process  assessment  and implementation of an effective Allergen Control Plan (including good manufacturing procedures, sanitation and training). If it is concluded that inadvertent cross-contamination  can  not  be  eliminated,  then precautionary  allergen  labeling  is  appropriate.
Precautionary allergen labeling is never to be used as  a  substitute  for  good  manufacturing  practices and an Allergen Control Plan.

Attached File  Components of an Effective Allergen Control Plan.pdf   210KB   13 downloads

 

 


Kind Regards,

 

Charles.C


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Posted 19 May 2021 - 08:02 PM

I don't understand any of the scenarios.  If a manufacturing has a valid allergen control program in place none of those scenarios would apply.  It seems to me, manufacturers are using the may contains statement as a crutch for their allergen control program, or they simply don't understand the use of the statement.

 

 

Quote

There are currently four scenarios of using PAL:-

Scenario 1: PAL-labelled food products that have a genuine risk of causing allergic reactions
Scenario 2: Products where there is no serious allergenic risk involved, but manufacturers may feel obliged to ensure that labels carry the warning to cover even the potential of a minor risk
Scenario 3: Products that would not carry PAL because there is no risk of allergenic contamination, but there is concern that consumers would be confused when they cannot find PAL on a product, so as a result, it is included.
Scenario 4: Products where manufacturers are actually unaware of the actual need for PAL
 

(Scenario 3 sounds highly improbable to me)






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