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

Started by , Apr 24 2022 06:59 PM
2 Replies

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!

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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.

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 -

Food Grade Sanitizers.pdf   143.74KB   19 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. 


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