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Are Allergen Statements Required for Non-Food-Grade Chemicals, Chemical Classifications

Sanitation Chemicals allergens BRCGS BRC allergen statement

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Jon19

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Posted 24 April 2022 - 06:59 PM

We are a food manufacturer in the US and BRCGS Certificated. 

 

We currently have 3 chemical categories (food-grade, incidental food-grade, and non food-grade). We currently classify chemicals as the following:

 

1. Food Grade - includes sanitation chemicals, and food-grade greases, may be used on food-contact surfaces

2. Incidental Food-Grade - includes lubricants that are used on machines that may accidentally get into product (ex. motor above a filler). May be used on production equipment, but not on food-contact surfaces

3. Non Food-Grade - chemicals that cannot be used on a food-contact surface or on production equipment

 

I'm hoping to clear up a question on the requirement for allergen statements for chemicals. Is this just for food-grade chemicals or for all chemicals listed in all categories I've listed. It's challenging to get allergen statements for some of what we consider non food-grade chemicals.

 

Also, I'm hoping someone can clarify how sanitation chemicals are usually categorized. I believe I've heard that the food-grade category should only include chemicals that may touch food intentionally vs chemicals that are used on food-contact surfaces but should not outright touch food.

 

The only comments from our past auditors has been that food-grade lubricants need to be stored in a separate locked cabinet, but nothing to indicate that sanitation chemicals should not be labeled as food-grade chemicals.

 

Any clarification on these questions would be appreciated!



beautiophile

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Posted 25 April 2022 - 01:19 AM

Short answer: yes for all chemicals.

Long answer: you can keep the allergen declaration deep in company's drawer, just in case you are asked by an auditor/inspector who lacks the common sense, I don't think scientific researchers have ever had people swallow industrial chemicals to make comprehensive studies of their specific allergic reactions then put the results in datasheets.


Edited by beautiophile, 25 April 2022 - 01:24 AM.


Charles.C

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Posted 25 April 2022 - 04:50 AM

We are a food manufacturer in the US and BRCGS Certificated. 

 

We currently have 3 chemical categories (food-grade, incidental food-grade, and non food-grade). We currently classify chemicals as the following:

 

1. Food Grade - includes sanitation chemicals, and food-grade greases, may be used on food-contact surfaces

2. Incidental Food-Grade - includes lubricants that are used on machines that may accidentally get into product (ex. motor above a filler). May be used on production equipment, but not on food-contact surfaces

3. Non Food-Grade - chemicals that cannot be used on a food-contact surface or on production equipment

 

I'm hoping to clear up a question on the requirement for allergen statements for chemicals. Is this just for food-grade chemicals or for all chemicals listed in all categories I've listed. It's challenging to get allergen statements for some of what we consider non food-grade chemicals.

 

Also, I'm hoping someone can clarify how sanitation chemicals are usually categorized. I believe I've heard that the food-grade category should only include chemicals that may touch food intentionally vs chemicals that are used on food-contact surfaces but should not outright touch food.

 

The only comments from our past auditors has been that food-grade lubricants need to be stored in a separate locked cabinet, but nothing to indicate that sanitation chemicals should not be labeled as food-grade chemicals.

 

Any clarification on these questions would be appreciated!

Hi Jon,

 

FWIW - Yr chemical classification system possibly needs some Validation, eg compare -

 

But the truth is, the term “food grade” is one that can be loosely used.

https://www.nsf.org/...ary/food-grade-lubricants-registrations

 

Food grade means that the material is either safe for human consumption or it is okay to come into direct contact with food products.

 

https://www.industri...d-safe-meanings

 

Choosing materials that are “food-safe” can be just as important as choosing materials that are “food-grade”.

https://foodsafetyte...ways-food-safe/

----------------------------------------------------------------------------------------------------------------

Regarding ^^^^(blue) -

 

Here is one US-oriented interpretation -

Attached File  Food Grade Sanitizers.pdf   143.74KB   9 downloads

Also see -

https://www.accessda...cfm?fr=178.1010
 

 

In its simplest definition, a food-grade chemical is an additive that is safe for consumption

https://bremeringred...rade-chemicals/

 

(yr "belief" maybe related to lubricant classifications ?)

 

Offhand, I suggest caution in referring to any chemicals as "Food Grade" unless (Context/Safety) Validatable. 


Kind Regards,

 

Charles.C






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