Allergen Products & Labeling, CCP?

Hello all,

I am working on a mock HACCP plan for a class I am taking and I am having some difficulty figuring something out. The product is salad dressing and contains products such as eggs, dried milk, and yellow #5. But it also says that not all products produced contain these ingredients. Also, it says that a "common label" is used on all products with the only difference being the ingredient statement and flavor designator. So my question is, would labeling of the product be considered a CCP since it is cruicial that the correct ingredient statement is placed on the product since some of the ingredient contain allergens on some products and not on other?

Thank you in advanced for all your help!

Tracy

Hello all,

I am working on a mock HACCP plan for a class I am taking and I am having some difficulty figuring something out. The product is salad dressing and contains products such as eggs, dried milk, and yellow #5. But it also says that not all products produced contain these ingredients. Also, it says that a "common label" is used on all products with the only difference being the ingredient statement and flavor designator. So my question is, would labeling of the product be considered a CCP since it is cruicial that the correct ingredient statement is placed on the product since some of the ingredient contain allergens on some products and not on other?

Thank you in advanced for all your help!

Tracy

Dear TracyL,

Regarding the hazard due to allergens, There are typically 2 alternative approaches in traditional haccp analyses.

Yr query is potentially a mixture of legislation, standard involved, and risk assessment methodology. All of these may inter-relate to yr location and product. I am not familiar with any specific USA restrictions for yr product so my comments are sort of general.

If allergens are introduced in the process, some people regard the labelling step as a Prerequisite and some a CCP. IMEX (not USA), especially where the allergenic material unavoidably derives from the input ingredients, prerequisite is more usual classification but see a specific counter example below (2nd attachment).

If there is no hazard from allergenic factors and no other perceived hazards/significant risks associated with or controlled by the labelling step then should be no reason for CCP.

These USA-oriented attachments are not for salad dressing but the allergen discussion is probably typical. However you need to specifically check if the situation is different (eg legislatory) for salad dressings in yr case and also as per my opening comments.

 addressing allergens in meat products.doc   39KB   88 downloads

 Example, NSF food safety, Quality and defence audit.pdf   116.35KB   124 downloads
(see pg13, para6)

Rgds / Charles.C