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Allergen testing of the product due to a customer complaint

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RajaBD

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Posted 23 November 2023 - 03:51 AM

Our company is located in the United States. Our product does not contain allergen ingredients. However, one of our finished products includes a cheese pouch that is purchased from another company. Samples of finished products, as well as raw materials, remain in our possession until the end of the product's shelf life.
 
In the event that any allergen complaints are received, we send the finished products, including raw materials, to a third party lab for testing. Our company has recently hired a senior manager. This manager has advised me not to test finished products for allergens if we receive an allergen complaint, since if the results are positive, the product will have to be recalled. This individual suggested that only the allergen preventive control should be shared with the customer. The person's previous company suffered a large recall as a result of the allergen issue. 
 
It is my opinion that it is a totally wrong idea not to send the retained samples to an independent laboratory for allergen testing. It would be greatly appreciated if you could let me know what you think.
 
Thank you.


MOHAMMED ZAMEERUDDIN

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Posted 23 November 2023 - 04:41 AM

Cheese Pouch or Cheese Powder? Kindly clear it. If it is pouch then allergen declaration is a must on it.



Scampi

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Posted 23 November 2023 - 01:05 PM

your boss in wrong and that is a bull**** response-I guess they don't care about the end consumer at all

 

I know in Canada this is one of the reasons for an investigation into the finished goods

  • Complaints from consumers, industry, other government departments or associations

https://inspection.c...5/1332207914673


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SQFconsultant

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Posted 23 November 2023 - 01:49 PM

Nothing like a new senior manager, huh - wonder what the reason was that he left the former company.

 

Anyway, that one is a no-go, he is wrong - I would tell him, if he plans on making a policy on this that it be put into writing - if its a sticking point for him and he will not budge at least you'll have it in writing with his signature, that way when the SHTF at least you have protection and yes as someone else said -- he lacks complete thought to the customer.


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jfrey123

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Posted 27 November 2023 - 05:10 PM

Oh boy, what a scary approach...  If you receive a substantiated complaint for something as serious as an undeclared allergen, you should be doing everything in your power to investigate.  In the situation you're describing, I suspect you'd have received ingredients made by suppliers that are supposed to be allergen free, and the concern is the potential that supplier sent you a contaminated product.  Letting that product continue to go out into the world is just asking for potential deaths, and wrongful death lawsuits are WAY more expensive than a recall.

 

Hopefully you're never in the spot to have to test for an allergen complaint.  If you are, I hope you do the right thing and this new manager be damned.



SHQuality

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Posted 28 November 2023 - 01:04 PM

Why were you only sending the product out when there was a complaint? If you test BEFORE it is sent to the customer as part of the release testing, you can avoid the complaint altogether.

 

Even better, if your supplier can't control the allergen risk in their product, then perhaps they should be the one doing the testing (and paying for it).



jfrey123

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Posted 28 November 2023 - 05:09 PM

Testing as a condition of finished product release can be an overt burden, especially against limited shelf-life products.  I'd best most of us have a hard time getting budget approval for additional testing unless there is an articulatable risk in a specific circumstance.  I'd dare say if one feels they need to test every batch of product for undeclared allergens, their supplier approval program isn't doing its job.

 

I normally control undeclared allergens through our supplier approval program:  letters of guarantee the raw material is not adulterated, allergen questionnaires to determine if a shared line poses a risk, copies of their allergen control programs or a statement regarding allergens, etc.  For customers who tell me a shared line is used, we will sometimes send samples for testing, for allergen and/or micro, as part of the supplier scoring system to verify we can trust the product supplied.


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SQF beginner

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Posted 29 November 2023 - 09:15 PM

isn't cheese pouch/powder inherently milk/dairy allergen? Or are you just storing it near your non-allergenic ingredients? Sorry for being confused...



SHQuality

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Posted 29 November 2023 - 10:40 PM

In the event that any allergen complaints are received, we send the finished products, including raw materials, to a third party lab for testing. 

What allergens are typically the ones complained about?

Surely, you're not testing cheese on milk allergen presence?



G M

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Posted 29 November 2023 - 10:55 PM

 

Our company is located in the United States. Our product does not contain allergen ingredients. However, one of our finished products includes a cheese pouch that is purchased from another company. Samples of finished products, as well as raw materials, remain in our possession until the end of the product's shelf life.
 
In the event that any allergen complaints are received, we send the finished products, including raw materials, to a third party lab for testing. Our company has recently hired a senior manager. This manager has advised me not to test finished products for allergens if we receive an allergen complaint, since if the results are positive, the product will have to be recalled. This individual suggested that only the allergen preventive control should be shared with the customer. The person's previous company suffered a large recall as a result of the allergen issue. 
 
It is my opinion that it is a totally wrong idea not to send the retained samples to an independent laboratory for allergen testing. It would be greatly appreciated if you could let me know what you think.
 
Thank you.

 

 

Your previously existing program sounds right to me.  If/when you suspect a problem due to customer/consumer complaint you can submit a retained sample for additional testing that is not normally considered necessary due to existing preventative controls.  

 

The whole point is that the complaint suggests your preventative controls may not have worked, and the test can help determine if that is or is not the case.  Under legal regulations and most certification schemes like GFSI you are obligated to take reasonable measures to review and reassess when you receive complaints of a serious nature like allergen cross contamination.  Just forwarding the complainant your preventative program does not do that.



Hoosiersmoker

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Posted 01 December 2023 - 07:34 PM

Sounds like this senior manager could easily cost you your certification. The investigation isn't just to determine if there is an issue, but that if there is an issue, it gives you the opportunity to determine how it happened and to take measures to prevent future issues. It almost reminds me of the Peanut Corporation of America "Just ship it, we can't afford to lose another customer...". But can you afford to close the doors because you knew there was potentially an issue and refused to recall? Seems like a big risk! BTW the Parnell brothers are still in prison...





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