General Mills
Food Safety & Regulatory Matters
Subject:  Food Allergens    Number: POLICY 8
           
Effective Date:  2/13/03    Replaces: Food Allergens (05/07/02)
           
Policy Statement:
General Mills is committed to ensuring proper labeling of allergens during development, production, marketing, and distribution of all General Mills products in order to prevent potential adverse health effects among allergic consumers.
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    NOTE:  Click the following hyperlink to Corporate Policy CP-7.
         
SCOPE:
This policy applies to all General Mills facilities, operations, employees, and products including those produced, stored, handled, or packaged under contractual agreement.  Partnerships and/or joint ventures representing at least 50% General Mills ownership are expected to develop and maintain policies and standards that are consistent with this policy.  Exceptions must have the written approval of the Vice President of Quality and Regulatory Operations.
Policy Requirements:
1.    Food Allergens: Peanuts, tree nuts, milk, eggs, soy, wheat, fish, and crustacea, cause the majority of all serious food allergic reactions.  These “Top Eight” or “Big Eight” plus any others selected by General Mills as key “Food Allergens” must be strictly controlled and lab
eled in our products.
    NOTE: Click the following hyperlink to Form 8.1a List of Allergenic Ingredients for details.
2.    Education: It is necessary for General Mills employees, partnerships, joint ventures, and others contracted by General Mills to have a clear understanding of the risks associated with food allergens. 
Allergen Management Strategy
1.    Strategy: General Mills uses three primary strategies to manage production of allergen- containing products.  These strategies are listed here in order of preference and need to be supported by adequate ongoing training and documentation:
∙ Dedicated Systems - Equipment and systems producing products that contain food allergens are dedicated exclusively to products containing that food allergen.
∙ Separation - Equipment and systems producing products that contain food allergens are separated from non-allergen products and systems.  Separation can be accomplished by (a)physical barriers, (b)production scheduling and/or (c)sanitation Standards.  Specific ‘separation’ protocols are required on each non-dedicated system as the primary means of preventing inadvertent allergen cross-contact resulting in unlabeled allergens. 
∙ Labeling – Supplemental labeling of products with non-formulated allergens (herein after referred to as “cross-labeling”) is required when line or system dedication, separation, (physical, scheduling, and cleaning) strategies aren’t effective or when the form and type of allergen presents significant consumer risk.  Such labeling will not be used in lieu of Good Manufacturing Practices.

2.    Labeling:  All General Mills consumer information regarding products containing food allergens shall be centered around the use of a current ingredient statement that accurately identifies all potential General Mills food allergens. Food allergens must be clearly labeled i
n the ingredient listing on all General Mills products including those used as components of other ingredients or products.
    Labeling methods to alert allergic consumers to new or similar products that contain allergens must be incorporated into product introductions. 
    Cross-labeling strategies can be used to reduce consumer and company risk in regard to allergens.  This strategy can also impact the level of cleaning performed, but will not replace the following of Good Manufacturing Practices and still mandates “due diligence” cleaning practices.
    Those General Mills products that are regulated by USDA must bear labels that comply with USDA regulations and have USDA approval.
3.    Cleaning Practices:  “Allergen clean” system changeovers are required from allergen- containing products to non-cross labeled products and on systems where peanuts, tree nuts, and shellfish are present.
    NOTE: Click the following hyperlink to Standard 8.1 Food Allergens for more information.
4.    Rework: Rework control and documentation are essential to avoid accidental product mixing and to assure compliance with food safety, regulatory, and quality requirements.
    Rework, refeed, recoup, or regrinds which contain a food allergen should be eliminated whenever possible and strictly controlled and documented to prevent contamination of other non-allergen products.
    Each facility shall have clearly defined areas for staging and storing of rework products that contain food allergens.  Any storage of food allergen rework outside of designated staging or storage areas is not permitted.