As part of being in compliance with the Preventive Controls regulations, the company would have an allergen preventive control for labeling. A difficulty here is that someone improperly stored pre-labeled cartons on the wrong pallet, perhaps these cartons were from a previous production run, and at the end of that production run, the remaining unused cartons were returned back to the label storage area and improperly placed on the pallet of gluten-containing cartons. It is easy to see how a box or two of cartons on the pallet could have been missed, even if there were some checks in place at the point of labeling. The allergen preventive control at the point of labeling needs to address this type of situation. This could include an entire pallet check, a control component for the return of unused labels, and/or an inline bar code reader.
https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/urgent-food-recall-vans-gluten-free-original-waffles-due-potential-presence-undeclared-wheat
Urgent Food Recall of Van’s Gluten Free Original Waffles Due to Potential Presence of Undeclared Wheat Allergen
Summary
Company Announcement Date: July 03, 2023
FDA Publish Date: July 03, 2023
Product Type: Food & Beverages
Reason for Announcement: Undeclared Wheat
Company Name: Van’s International Foods
Brand Name: Van’s
Product Description: Gluten Free Original Waffles
https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/urgent-food-recall-vans-gluten-free-original-waffles-due-potential-presence-undeclared-wheat
Urgent Food Recall of Van’s Gluten Free Original Waffles Due to Potential Presence of Undeclared Wheat Allergen
Summary
Company Announcement Date: July 03, 2023
FDA Publish Date: July 03, 2023
Product Type: Food & Beverages
Reason for Announcement: Undeclared Wheat
Company Name: Van’s International Foods
Brand Name: Van’s
Product Description: Gluten Free Original Waffles