6 replies to this topic

[Techie25]

Hi all, looking for some advice on allergens. Our products have May contain Milk PAL statement because it is a dusty environment and in this moment and time it is impossible to segregate the production lines to prevent milk powder dust contamination. Therefore, May contain statement was added. We do routine allergen testing and sometimes milk is detected in the product where it is not an ingredient. Business feels comfortable releasing products containing milk as finished product has May Contain statement, however I am not on the same page. May Contain and Do Contain are two different things. What are your thoughts on this?

I assume if the product would be tested by retailer or enforcement agency it would need to be recalled despite of May Contain on the pack?

 

Thank you

Edited by Renatika, 12 March 2025 - 04:05 PM.

[G M]

...We do routine allergen testing and sometimes milk is detected in the product where it is not an ingredient. ...

 

That is a problem.  Once you know it is contaminated there is an obligation to do something about it.

 

"may contain" is not an excuse for poor sanitation or segregation.

[SQFconsultant]

Under the circumstances that MAY CONTAIN statement is their trap to be charged with fraud.

 

Tell your ownership to get off the May contain pot and spend the money on segregation.

 

What is the reasoning to allow a DUSTY situation to exist?

[jfrey123]

I'd resign because I don't like wearing shiny chain bracelets.  You have existing knowledge that adulterated product was discovered, and you have knowledge that you're failing to protect product from unintentional allergen cross-contact.  Maybe I'm overreacting but if it's at a detectable level in product analysis then it's very likely it can cause harm.

[MDaleDDF]

Hi all, looking for some advice on allergens. Our products have May contain Milk PAL statement because it is a dusty environment and in this moment and time it is impossible to segregate the production lines to prevent milk powder dust contamination. Therefore, May contain statement was added. We do routine allergen testing and sometimes milk is detected in the product where it is not an ingredient. Business feels comfortable releasing products containing milk as finished product has May Contain statement, however I am not on the same page. May Contain and Do Contain are two different things. What are your thoughts on this?

I assume if the product would be tested by retailer or enforcement agency it would need to be recalled despite of May Contain on the pack?

 

Thank you

add .01% milk to the product moving forward, and add it to the ing statement. 

 

for your current situation, you need to recall it imho.   May contain does not absolve the company in any way, and as I said in another post this week, is a very dubious thing.  You have product on the market with an undeclared allergen.   Plain and simple.

Edited by MDaleDDF, 12 March 2025 - 06:15 PM.

[AltonBrownFanClub]

In my opinion, you have a moral obligation to report this to your regulating body.

From a legal standpoint, I believe the same.

 

Here is the guidance for precautionary allergen labeling in the United Kingdom.

https://www.food.gov...ergen-labelling

Page 1, "Our precautionary allergen labelling checklist provides more information on the steps food businesses should take when applying precautionary allergen labelling."

Page 2, "PAL should not be used as a substitute for good food hygiene and safety practices."

Page 6, "Precautionary allergen labelling should only be used where a risk of allergen cross-contamination has been identified that cannot be removed. It should not be used as a substitute for good manufacturing practices."

 

Here is the checklist:

https://www.food.gov...lling-checklist

Page 2, "6. When to apply PAL Using a PAL is advisable when an unavoidable and real risk of allergen cross-contact is identified that cannot be removed through risk management actions, such as separation or cleaning."

 

Separation and cleaning are both required.

Your company is not doing an acceptable job of separating nor cleaning.

This is proven, scientifically, with your test results. 

 

If you or your company does nothing, you are being complicit in their crime.

Edited by AltonBrownFanClub, 12 March 2025 - 06:31 PM.

[Techie25]

Thank you everyone! Your comments are very valid and support my stance! It is dangerous and irresponsible. It is difficult when those kind of decisions are made by someone above you but all efforts are being put to make the business understand the risks and moral obligations.