Best practices for food manufacturing

**Update 04/19/2018**

**Update 2 04/26/2018**

This was going to be a part of my AMA and FAQ, but when I started responding to her to explain best practices for food manufacturing it started getting long so I made it into its own article.

Recently I got some feedback from one of my viewers, Diana. She wrote

“FYI, chocolate chips by ghirardelli, guittard, hershey and other general chocolate makers are not vegan. These companies use the same equipment to make milk chocolate and dark chocolate and DO NOT clean the equipment in between batches of milk and dark chocolate. So there will be a significant amount of milk in the dark chocolate. You have to buy from a company with separate equipment for dairy free chocolate to get vegan chocolate. Enjoy Life makes vegan chocolate chips.”

I think that there is some misinformation out there about labels and what they mean. As a means to cover their ass from lawsuits and to inform people with allergies they will state that a product that may not have an allergen in it is processed and stored on or near the same equipment and room so if there are any molecules of that allergen that comes in contact either physically or in the air of the product and you are highly allergic you can weigh the risk of having an allergic reaction.

The best practices for food manufacturers is to clean equipment in between all batches of product made, as well as personal hygiene, cleanliness, and sanitation. This helps prevent food borne illness and cross contamination of food. The FDA and local health government agencies has rules and guidelines for manufacturers that are required to obey as well.

Large companies hire people whose only job is to sanitize equipment, and employees go through a process of cleaning and sanitising their person and clothes. I found a couple of articles from the food sanitation industry that has some best practices industry wide. Again these are best practices, but companies as big as those listed in the email are sure to follow these to keep their products healthy and allergen free. And when they are dealing with potential allergies, they are definitely going to clean and sanitise in between batches to prevent illness.

From Food Safety Magazine:

I also found a checklist for manufacturers to follow:

Further reading from the FDA Current Good Manufacturing Practices

Additionally there are many videos on Youtube that show procedures that manufactures go through to sanitise their equipment and workers. It is up to your own personal feelings about this whether to use these products or not. I understand if you don’t want to support these companies who use dairy or for other ethical reasons however I would trust eating something coming from a food manufacturer that is vegan whether explicitly stated on the package or not than from going to a non vegan restaurant and ordering and eating something there. The risk of cross contamination is far greater in a restaurant especially when busy than it will ever be from eating dairy free dark chocolate from Guittard. I am not going to stop eating out at my favorite restaurants.

I as a former chef and a vegan for more than half my life have researched or seen first hand what happens in food manufacturing plants, been in slaughterhouses and dairies as part of my culinary training, know how important and serious it is for these companies to keep people from getting sick and dying from either not cleaning their equipment properly or from allowing an allergen into a food that shouldn’t have that allergen. I am not trying to hurt people’s feelings, just trying to educate people so they have a better understanding why a label says that it is manufactured in the same facility or on the same equipment as dairy or nuts, or gluten, or whatever the case may be. That label is for those who may get very sick or die from being in contact with a minuet amount of that item, not that that product actually intentionally contains that allergy. For those the label will say it contains dairy. Also I am not saying that you should not do your due diligence and carefully read the ingredients because it still may contain honey, or another animal derived ingredient. Always read your labels, just understand what they mean.

I additionally reached out to the manufacturers she listed in her email and asked them:

“Hello, what are your policies for cleaning and sanitation of equipment in between batches? Especially when you are switching from one type of product to another, like milk chocolate to dark chocolate. Thank you.”

This was their replies:
From Hershey’s:

“We look for ways to manufacture allergen-containing products in separate manufacturing facilities. If it is not possible to use a separate facility, we try first to manufacture allergen-containing products in a separate area of the plant or to use dedicated equipment. If we are unable to use dedicated equipment, we follow government regulations called Good Manufacturing Practices as well as our own stringent requirements for thoroughly cleaning the equipment between product changes. Again, we use an Allergy Information Statement on a product when we have a concern about possible cross contact with an allergen.”

From Ghirardelli:

Thank you for reaching out. Unfortunately, the details of our cleaning policies are proprietary but we can share that all of our cleaning and sanitizing procedures meet the requirements set by the FDA. We hope this information is helpful to you. Our production facility follows proper GMP’s. However our facility is not a vegan plant, nor do we claim to be. Our products either contain dairy or are produced on shared equipment with dairy.

I reached out to Guittard via email, Twitter, and phone call and as of this posting they have chosen to ignore my questions. If they respond or decide to reach out, I will be more than happy to take a statement from them.

Update: Guittard finally got back to me on 4/18 and this was their response:

Hi, sorry for the delay in getting back to you! Guittard Chocolate Company is always concerned about cleaning and sanitation of our lines as this comprises a Food Safety issue. Our product is composed of mostly a fat system and is considered a shelf-stable product due to the low water activity. Because of this factor, it is necessary to clean belts with a non-water based system and we currently use iso-propyl alcohol. This removes the fat system and sanitizing the surface. Final cleaning can be validated by swabs from our in-house micro laboratory.

I replied back asking about their practices of cleaning in between batches especially going from dairy to non-dairy items, and will update when I receive a response from them.

**Update 2** They use bone char sugar!

Thank you for your inquiry. From your email address/business name I would like to address the term vegan. The term ‘vegan’ is not a standard of identity that is recognized by the FDA but I believe that you are concerned with products having no animal origin. The vast majority of both dark and milk chocolates manufactured here at Guittard contain milk protein because we use shared lines in the processing. Our tests indicate that the range of milk proteins left in dark chocolates is between 50-300ppm’s. Milk may not be an added ingredient for some products but milk allergens are present. Here is the statement that appears on these products: “Made on equipment also used to make milk chocolate; not suitable for individuals with milk allergies.” We do chocolate flushes, sanitize, and swab our equipment. On another note for vegan: our sugar is processed with bone char except for our organic products. I hope that I’ve been able to provide you some insight for you to make a decision on whether or not you are able to move forward with Guittard Chocolates.

If you have any additional questions or thoughts I would be more than happy to answer and hear them out. Do you eat at non vegan restaurants? Do you buy food from non vegan manufacturers?

What do you think?

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