9th Major Allergen FDA
Hey hey peeps--have a read if you have not already Sesame has been added to the FDA list of allergens
https://www.fda.gov/.../food-allergies
Thanks for the heads up Scampi! Be ready ya'll, looks like labeling requirements are effective January 1st, 2023.
I am curious on how everyone is going to handle labeling. Our risk assessment indicates we are incapable of eliminating sesame seeds 100% - seeds are small and can get into slicers and conveyor belts and could shake loose and one or two end up on a "non-sesame seed product". In our case, sesame seeds will be our only allergen (except wheat which is in everything we produce) and its one of many baked goods we produce so we might consider putting sesame seeds into our ingredient deck and our "may contain" statement like some of the very large bakeries are doing. What do you all think?
I would change your labelling absolutely.
Following one of the allowed labelling formats
The name of the food source of a major food allergen must appear:
In parentheses following the name of the ingredient.
Examples: “lecithin (soy),” “flour (wheat),” and “whey (milk)”
— OR —
Immediately after or next to the list of ingredients in a “contains” statement.
Example: “Contains wheat, milk, and soy.”
FDA guidance for the food industry states that advisory statements should not be used as a substitute for adhering to current good manufacturing practices and must be truthful and not misleading.
They've been on the horizon, and have been banned from my building for years now. I actually got rid of them just because they were such a pita, like Mister Mike says. They would lodge themselves in every part of our mixing and packing machines and we ditched them due to that, but they'd be gone anyways now!
I personally don't put much faith in may contain statements of any kind. Are they not legally dubious if something actually occurs? Maybe buy some sesame powder and put .01% into everything you make? I don't even know if there is such a thing, but as I've stated before, that's how I handle allergens here. We have 4, and they all 4 go into every product we make.
They've been on the horizon, and have been banned from my building for years now. I actually got rid of them just because they were such a pita, like Mister Mike says. They would lodge themselves in every part of our mixing and packing machines and we ditched them due to that, but they'd be gone anyways now!
I personally don't put much faith in may contain statements of any kind. Are they not legally dubious if something actually occurs? Maybe buy some sesame powder and put .01% into everything you make? I don't even know if there is such a thing, but as I've stated before, that's how I handle allergens here. We have 4, and they all 4 go into every product we make.
I wish it could work for any situation, but unfortunately it doesn't: say, in ice cream manufacturing it's impossible to put "a little bit of every allergen" in all ice creams, the ingredient list wouldn't look good (Mint Chocolate ice cream cannot contain sesame or peanut). Though, the idea is great!
I wish it could work for any situation, but unfortunately it doesn't: say, in ice cream manufacturing it's impossible to put "a little bit of every allergen" in all ice creams, the ingredient list wouldn't look good (Mint Chocolate ice cream cannot contain sesame or peanut). Though, the idea is great!
Yeahhhhhh, that's why I don't have celery in my building any longer. It wouldn't look real good on a waffle cone ingredient statement, lol.....
Be prepared.
It may take a while, but I'm hopeful that, at some point, the USA recognizes all 14 major allergens already recognized in the European Union now.
Won't affect my current company, but it's on our radar and I'm having my plants update their allergen policies well ahead of the due date. I did notice some products I buy in stores are already declaring sesame properly well ahead of the due date.
So,
I've been aware of this and I'm working on fixing labels of products our company produces in house - but what about stuff we distribute?
We do a lot of frozen distribution and have product from 2021, 2022 etc. and I just don't want to be caught totally off guard, but I would think anything produced before the effective start date would be exempt? I hope?
I would actually expect exemptions to depend on the date the product is brought into the market and distributed from your warehouse.
Besides, once the new allergen rule is implemented, you need to have your warehouse in order as well as the outgoing goods, so there's really no avoiding updating the labels (and informing customers with stock).
I would actually expect exemptions to depend on the date the product is brought into the market and distributed from your warehouse.
Besides, once the new allergen rule is implemented, you need to have your warehouse in order as well as the outgoing goods, so there's really no avoiding updating the labels (and informing customers with stock).
I guess one of my hang-ups is that we don't add an additional allergen declaration label to some of our distributed products due to the fact that the manufacturer's label should have the appropriate declarations. So I was trying to figure out if I needed to figure out additional labeling for some things we otherwise wouldn't have labeled.
I guess one of my hang-ups is that we don't add an additional allergen declaration label to some of our distributed products due to the fact that the manufacturer's label should have the appropriate declarations. So I was trying to figure out if I needed to figure out additional labeling for some things we otherwise wouldn't have labeled.
Good chance to reach out to your vendor's QA teams and inform them of the inventory you're holding for them. You'll need to label and segregate it internally (if you use color stickers or labels for the pallets, that would work), but the owners of those products are going to need to decide if they want to take them back or pay you to relabel/repackage it on their behalf. There would be some liability exposure if they ask you to send improperly labeled foods forward after the effective date of sesame allergen implementation.
So,
I've been aware of this and I'm working on fixing labels of products our company produces in house - but what about stuff we distribute?
We do a lot of frozen distribution and have product from 2021, 2022 etc. and I just don't want to be caught totally off guard, but I would think anything produced before the effective start date would be exempt? I hope?
The FASTER Act was passed in April of 2021. Part of the 20 month delay to January 2023 as an effective date was for the reasons you mentioned and the shelf life of existing products.