New Product may contain Soya

Hello all,

We are currently looking into expanding our products, we are not a soy facility. We have found an ingredient that does not have soy listed, but it says it may contain Soya.

How could this be handled, can we use this product with our SQF certification?

or must we find something that is soy free?

Ah, the infamous "may contain" meant to highlight risks associated with shared production lines within a plant.  So long as the soy is not in the product you are purchasing, it should still be acceptable for you to use.  But based on the fact they're hitting you with a "may contain", I'd be requesting a copy of their allergen handling/sanitation procedures and asking for a statement that products you purchase are free from soy.  We send an allergen letter to our suppliers asking what allergens they handle, and whether each specific allergen is on a shared line or in the product we purchase.

That said, if you can find the product from a supplier who doesn't handle soy, that would be better for you overall.  By continuing to use this with a "may contain" on the label, your products are at risk if this supplier ever has to issue a recall for cross contamination.

If my facility was soy free, I wouldn't do it. 

If your supplier is using PAL, you need to assume the product does in fact contain soy. For reasoning, I'll refer you to a very tragic case still wending its way through the court systems: 

https://allergenbure...allergy-death/ 

In essence, a manufacturer of coconut yogurt disregarded the PAL on one of their ingredients, which stated 'may contain milk'. They did not carry the PAL over to their packaging, and they did not have a particularly robust process in place for checking the ingredient for traces of milk. Eventually, a batch of yogurt went to market with enough milk in it to cause fatal anaphylaxis for a customer.  

It's not to say you must avoid this ingredient at all costs — but you must assume there is a risk of soy contamination in the product and take the appropriate steps. Or find a different supplier. 

Another Question: If we choose add this ingredient that may contain soy, but we test EACH batch for soy before being packaged, and tag each to be tested during pre-op. Would this need to be included as a CCP or just an SOP for allergen?

Ah, the infamous "may contain" meant to highlight risks associated with shared production lines within a plant.  So long as the soy is not in the product you are purchasing, it should still be acceptable for you to use.  But based on the fact they're hitting you with a "may contain", I'd be requesting a copy of their allergen handling/sanitation procedures and asking for a statement that products you purchase are free from soy.  We send an allergen letter to our suppliers asking what allergens they handle, and whether each specific allergen is on a shared line or in the product we purchase.

 

That said, if you can find the product from a supplier who doesn't handle soy, that would be better for you overall.  By continuing to use this with a "may contain" on the label, your products are at risk if this supplier ever has to issue a recall for cross contamination

If your supplier is using PAL, you need to assume the product does in fact contain soy. For reasoning, I'll refer you to a very tragic case still wending its way through the court systems: 

 

https://allergenbure...allergy-death/ 

 

In essence, a manufacturer of coconut yogurt disregarded the PAL on one of their ingredients, which stated 'may contain milk'. They did not carry the PAL over to their packaging, and they did not have a particularly robust process in place for checking the ingredient for traces of milk. Eventually, a batch of yogurt went to market with enough milk in it to cause fatal anaphylaxis for a customer.  

 

It's not to say you must avoid this ingredient at all costs — but you must assume there is a risk of soy contamination in the product and take the appropriate steps. Or find a different supplier. 

Hi Emily.

Simple query - What is "PAL"  ? {I presume xxLabelling]

(afai can see, not mentioned in yr link)

Hi Emily.

 

Simple query - What is "PAL"  ? {I presume xxLabelling]

(afai can see, not mentioned in yr link)

precautionary allergen labeling.    

Hi Emily.

 

Simple query - What is "PAL"  ? {I presume xxLabelling]

(afai can see, not mentioned in yr link)

This industry is getting too acronym friendly.....

Sorry Charles for the delay, glad someone else was able to respond already — I probably should have just called it a 'May Contain' statement. 

Hi Emily.

 

Simple query - What is "PAL"  ? {I presume xxLabelling]

(afai can see, not mentioned in yr link)

Sorry Charles for the delay, glad someone else was able to respond already — I probably should have just called it a 'May Contain' statement. 

Agree with emportllc, you should mention the "May Contain" also on your product spec or label