Allergen Dilemma/Question

Hello All,

So i am working on the allergen section of the SQF (we are trying to be level 1) and the production manager, the owners, and QA (me) got into a dilemma. We have the following allergens in our facility: WHEAT,SOY,MILK,EGGS, PEANUTS, TREE NUTS. our labels say it contains:________________________ and it MAY CONTAIN : PEANUTS AND TREE NUTS(since not all our products contain tree nuts and peanuts). Our cakes are frozen in an open space and the racks are uncovered, both non and allergens are mixed, but they should not due to the allergens. there are many problems in which we would not follow the allergen program (we are limited in space/small bakery). The owner came up with the following "solution": what if we simply state : CONTAINS: WHEAT,MILK,EGGS,SOY,TREE NUTS,PEANUTS to all our labels (even though they may not have the tree nuts and peanuts) and that should be enough.

What are your guys opinion on this? Can we even do this? add all the allergens, even though it wont contain the peanuts and tree nuts? 

Any solutions? can someone let me know their allergen procedure? what you guys do? i need some major help.

Thanks!

IMO over declaring is not a problem.

You could also have a allergen cross contamination prevent plan/policy(color coded racks/designated areas) sanitation program with protein tests after changeovers or designated nut free equipment's. HACCP plan covering nut free areas and cross contamination points, employee training, protecting clothing e.t.c

We over declare SOY (lecithin) in our labels

Hello All,

 

 

So i am working on the allergen section of the SQF (we are trying to be level 1) and the production manager, the owners, and QA (me) got into a dilemma. We have the following allergens in our facility: WHEAT,SOY,MILK,EGGS, PEANUTS, TREE NUTS. our labels say it contains:________________________ and it MAY CONTAIN : PEANUTS AND TREE NUTS(since not all our products contain tree nuts and peanuts). Our cakes are frozen in an open space and the racks are uncovered, both non and allergens are mixed, but they should not due to the allergens. there are many problems in which we would not follow the allergen program (we are limited in space/small bakery). The owner came up with the following "solution": what if we simply state : CONTAINS: WHEAT,MILK,EGGS,SOY,TREE NUTS,PEANUTS to all our labels (even though they may not have the tree nuts and peanuts) and that should be enough.

 

 

What are your guys opinion on this? Can we even do this? add all the allergens, even though it wont contain the peanuts and tree nuts? 

 

Any solutions? can someone let me know their allergen procedure? what you guys do? i need some major help.

 

 

 

Thanks!

Hi shyshadow,

I'm not in USA but based on the general Literature I thought the "solution" you describe is (rightly or wrongly) more like the normal situation.

The Regulatory/Other viewpoints are discussed in this thread/post -

http://www.ifsqn.com...indpost&p=91160

It sounds reasonable on the surface, however this will of course effect a bunch of other documents and could make for a sticky situation in the event of a needed trace or recall situation.

We've had this with some of our clients and have been able to work up allergen plans even in small bakeries.

It might be ok considering that level one is not GFSI, but then again I don't quite understand why a company with all of these allergens is doing level 1 and not level 2.

Glenn Oster

Hi Glenn,

I rather had the impression that this labelling technique has now become routine, eg -

We know this type of labelling is not liked by consumers but currently it is the only way for food manufacturers to inform consumers if there is a possibility that an allergen which is not part of the final product may be present in the food. In the future, some restrictions may be placed on the use of precautionary labels but that is not yet the case.

Does GFSI specifically oppose this practice ?