Sulphites at 60ppm in Ingredient used at 1% in finished product

Hello, 

We are in process of approving a flavour ingredient which contain sulphites at 60ppm. The flavour is expected to be used at 1% in the finished products (breads/ muffins), so for Canadian labelling, since sulphites in finished product would be <10ppm, I do not need to declare suphites on the label. But I am concerned about allergen control program reviewal. I would need to review my allergen control program since I am introducing a new allergen, sulphite, above threshold in my bakery, but would I need to implement controls such as scheduling, equipment cleaning, swabbing, etc. even though it is used in low percentage (<1%) in our recipe? 

I'm not Canadian, but my gut is telling me yes.  If it's considered an allergen under Canadian regs, then it should be treated as such in your allergen control program.  Finished product labeling regs are different than GMP's, and I'm betting your program would require all of the allergen controls if the ingredient was peanut instead of sulphites.