Controls for Allergen Cross Contact Between Crustacean and Mollusc
Looking for some technical feedback on allergen cleaning validation for my client who processes both raw lobster (crustacean) and raw sea cucumber (mollusc/echinoderm). I am trying to wrap my head around whether the cleaning of common equipment in between processing these two species requires to be validation in terms of removal of allergens. In Canada, they are both lumped under the common allergen heading "crustaceans and molluscs". These products are primarily destined for export to China where both of these species are lumped under "shellfish". Having said that, I know that individuals can be allergic to crustaceans but not mollusks, and can be allergic to mollusks but not crustaceans. Any insight that you can provide would be much appreciated.
My familiarity with Canadian regs is somewhat limited, but my understanding is that the allergen should be declared specifically as the common name of the species in question, for these "groups" of allergens such as nuts or shellfish/molluscs. See e.g. https://inspection.c...5/1462472833650
Presence of undeclared sea cucumber in lobster, or vice-versa, could therefore potentially be a labelling issue as well as a risk to consumers with an allergy to the undeclared allergen if there is a risk of cross-contamination from unvalidated cleaning.
I guess you could look at "may contain" statements, but this CFIA page suggests these should only be used where all reasonable measures have been taken but aren't sufficient to fully control the risk:
https://inspection.c...52326591?chap=4
Whilst I don't know CFIA's view on this (one of the Canadian forum members might have more input on this area), this page does state that "may contain" isn't an alternative to GMP, so I'd be surprised if they weren't expecting to see validation of cleaning controls or justification as to why this isn't possible.
Not entirely clear to me whether OP was intended to be a BRC query or Regulatory (which would anyway presumably supercede if such exists).