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Precautionary allergen labeling and allergen changeover cleaning


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#1 Lisazitiello

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Posted 10 June 2021 - 08:18 PM

Hello, the company I work for repacks frozen food products such as frozen breakfast sausages or frozen cookie dough pucks that are manufactured by national companies. Our company receives bulk cases of frozen product from a manufacturer and portions the frozen items into smaller packages as a service to the larger manufacturing company. We do not own or sell the food products, we provide a service of repackaging their product into smaller units that the manufacturing company uses for sales representative samples. We practice a robust allergen program to both prevent cross contact and assure proper labeling.  We are SQF certified. Additionally, we do our best to set a daily production schedule that proceeds from items containing no allergens to those with like allergens then those with unique allergens.  If scheduling does not allow for that, we perform thorough allergen change over cleaning between products. The manufacturer provides ingredient listings and allergen labeling. Some manufacturers include a "may contain" precautionary allergen statement, such as "manufactured in a facility that also handles soy", as an example. We follow through with precautionary labeling when we place a label on the sample package. My question is, do we have to perform allergen cleaning based on the allergens actually included in the product only or do we have to include those allergens that are mentioned in the "may contain" precautionary statement, as if it were actually a "does contain" statement? I have always been advised that precautionary statements do not absolve a manufacturer from practicing proper GMP and SSOP's and therefore requires a manufacturer to prevent cross contact.  



#2 Bread_Head316

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Posted 11 June 2021 - 11:31 AM

if it does not contain the allergen in the actually product, I would suggest you do the cleaning



#3 Slab

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Posted 11 June 2021 - 12:53 PM

You are correct. Your allergen management program is risk assessed for existing allergens.

 

There is no point in risk assessment and following SSOP if we chase after nebulous and non-binding claims


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