Recent statistics show that approximately 20% of the US population is affected by a food allergy or food intolerance.  As the prevalence of food allergies and food intolerance continues to increase, consumer education and awareness as well as clear labeling of common allergens has become a priority for Turtle Mountain.  

Turtle Mountain has developed a strict, comprehensive allergen prevention program designed to validate the absence of undeclared food allergens in our products.  We remain committed to providing our consumers with the most accurate information regarding the practices and procedures we follow to ensure the quality and integrity of our products.  With this in mind we updated our packaging with the following allergen statement:

Turtle Mountain applies strict quality control measures in an effort to prevent contamination by undeclared food allergens.  To assure our preventative measures are effective, we sample test our product for the presence of gluten, dairy, peanut and almond allergens using state of the art testing methods.

This packaging change is presently underway and will ultimately affect all packaging with the exception of the Organic Soy Delicious novelties containing organic chocolate coating or organic chocolate chips.

We have also included a table of our product lines and flavors and any present allergens so you can more easily identify which products and flavors are right for you.  At the end of this section we have listed a few resources regarding food allergens we hope you will find helpful too.

ALLERGEN PREVENTION

Approximately 4% of the US population suffers from a food allergy while 15% of the US population is affected by food intolerance.1  What is the difference?  A food allergy is an abnormal response to a food that is triggered by the immune system.  The immune system sees the food or component thereof as harmful to the body and releases chemicals or histamines to protect the body.   These chemicals or histamines can cause a range of symptoms affecting the digestive, skin, respiratory or cardiovascular system and in some instances be fatal.1,3 On the other hand a food intolerance is a metabolic disorder where the body lacks the ability to breakdown a specific substance and causes an adverse reaction such as gas, bloating or abdominal pain.  One of the most familiar food intolerances is lactose intolerance.  In this instance the body doesn’t have enough of the enzyme lactase to break down lactose, a sugar found in milk, causing the symptoms noted above.2,3

ALLERGEN STATEMENT

Turtle Mountain Inc. remains committed to educating our consumers regarding the practices and procedures we use to ensure we provide our consumers with a safe, high quality product. Because our consumers eat our products for a variety of reasons, one being the avoidance of specific food allergens, Turtle Mountain believes it is important to include information regarding allergens on our packaging.  The allergen information was stated on our packaging as follows:

Turtle Mountain adheres to the highest standards of pasteurization, sanitation and kosher certification in the production of this product. This product was produced on equipment that also processes peanuts, tree nuts and dairy products.

While this did raise the awareness of our consumers, it also brought about more questions.    

In reviewing our allergen program we felt our allergen statement didn’t accurately convey the measures we take to prevent undeclared food allergens in our products.  We revised the allergen statement on our package to read as follows:   

Turtle Mountain applies strict quality control measures in an effort to prevent contamination by undeclared food allergens.  To assure our preventative measures are effective, we sample test our product for the presence of gluten, dairy, peanut and almond allergens using state of the art testing methods.

While we are taking every opportunity to convert all packaging over to the new allergen statement it is anticipated that consumers will be seeing both statements for a period of time.  The details of our allergen program as described below are the practices and procedures we follow and apply to our products no matter which statement appears on our package.  However, it should be noted that our Organic Soy Delicious novelties contain trace amounts of dairy which come from the organic chocolate coating or organic chocolate chips.  See the Organic Chocolate Challenges section below for more information.

We have included a table of our product lines and flavors and any present allergens so you can more easily identify which products and flavors are right for you. At the end of this section we have listed a few resources regarding food allergens we hope you will find helpful too. [ top ]

ALLERGEN PROGRAM

Our comprehensive allergen prevention program, designed to prevent any unwanted allergens into the product and to validate the absence of undeclared food allergens is structured as outlined below:

INGREDIENTS

We require all of our ingredient suppliers to provide a letter of guarantee as to the allergen content of the ingredient, whether the ingredient was processed on a line that contains allergens and whether the ingredient was processed in a facility that contains allergens. For those ingredients that are processed on lines that also process allergen containing foods, an allergen test is required, where possible, to verify that the ingredient is free from allergens.  Ingredients are then tested at random upon receipt at our warehouse or processing facilities for further validation.

PRODUCTION

Our products are manufactured in dairy facilities on the same equipment as dairy products.  Due to the inherent risk of contamination we require our manufacturing facilities to follow strict guidelines as outlined below. 

Warehousing: Ingredients are stored separately according to the allergens they contain. This prevents cross contamination.

Scheduling:  Production of our products is scheduled to prevent cross contamination between products.  Products using ingredients containing allergens are produced after products that do not contain allergens.  All scheduling is documented. Once a production line has been used to produce an allergen containing product, the line is fully cleaned – washed, rinsed, sanitized - and tested for food protein residue before another product is produced on the same line.

Equipment:  All cleaning procedures comply with the Good Manufacturing Practices set forth by the FDA.  All equipment is washed, rinsed and sanitized with a FDA approved sanitizing agent.  The pH of the rinse water is tested for the presence of any remaining detergent or sanitizing agent.  If the pH is not neutral the equipment is re-rinsed and the water retested.  Production does not proceed until a neutral pH is achieved.  Food contact surfaces are also tested after cleaning for any protein residue (casein for example) left on the line.  If the test comes back negative, then production can begin.  If the test comes back positive for residue, then the equipment is re-cleaned and re-tested. We do not proceed to production until the test comes back negative.  

Mix Testing: Prior to production our co-packers test the mix for the presence of dairy protein (casein and whey).  Results of this test must be negative (<10 parts per million) in order to proceed with production.  If the mix tests positive for dairy protein the mix will be rejected and disposed of properly.

FINISHED PRODUCT

Following production of our products Turtle Mountain’s Quality Assurance department sample tests finished product for the presence of dairy and where applicable gluten, tree nut and peanut allergens to ensure that the strictest standards for allergen control are being met.  Allergen tests of finished product must be negative for the product to be distributed.  A negative result indicates <10ppm for dairy, peanut and almond allergens, <20ppm for gluten allergens.  It should be noted that our Organic Soy Delicious novelties contain trace amounts of dairy which come from the organic chocolate coating or organic chocolate chips.  See the Organic Chocolate Challenges section below for more information. [ top ]

ORGANIC CHOCOLATE CHALLENGES

Turtle Mountain continues to face challenges as we strive to make all our products dairy-free. Our Organic Soy Delicious novelties contain trace amounts of dairy which come solely from the organic chocolate coating or organic chocolate chips.  While the amount of dairy in the organic chocolate coating and chips is small, it is greater than 10 parts per million. In spite of an exhaustive search we remain unable to locate a supplier of organic chocolate coating or chips which is produced on a dedicated non-dairy line.

Thus, in addition to the allergen statement referenced above the Organic Soy Delicious novelties contain an additional statement specific to the organic chocolate coating or chips.  It reads as follow:

This ingredient was produced on equipment used in processing dairy products and likely contains trace amounts of dairy.     

Why is a dedicated non-dairy line so important? The equipment used in making chocolate and chocolate products can not be cleaned effectively with water and detergent, which is the most accepted method used for cleaning food contact surfaces.  Water when combined with chocolate forms a gritty paste that is useless and difficult to handle. Therefore, the use of water for cleaning is avoided.  Instead, when a manufacturer wishes to switch from a dairy chocolate to a dark chocolate (non-dairy formula) the system must be flushed with large amounts of dark chocolate. Although this goes a long way in removing the dairy it is not 100%. Residual milk chocolate may still be in the system. As a result the dark chocolate may contain trace amounts of dairy protein. This residual milk chocolate has little impact on the quality of the dark chocolate but for those hypersensitive to dairy allergens it can be critical.  For those who suffer from lactose intolerance the amount of residual milk chocolate left in the system is minute and thus the amount of lactose negligible. Turtle Mountain does remain committed to sourcing a dairy-free organic chocolate.

Fortunately, we have found a manufacturer with a non-dairy chocolate line dedicated to running dark chocolate. It never runs milk chocolate and therefore the potential for cross contamination is eliminated. This has enabled us to create a line of novelties under our Purely Decadent Soy Delicious brand of products.  The chocolate coating used in these novelties has been tested and the results have confirmed the chocolate coating is dairy-free.  [ top ]

Want to Know More About Food Allergens?

We suggest you check out these resources for more information regarding food allergens.

The Food Allergy & Anaphylaxis Network (FAAN): www.foodallergy.org
Food Allergy Research & Resource Program (FARRP): www.farrp.org
FDA Center for Food Safety and Applied Nutrition - Information About Food Allergens: www.cfsan.fda.gov/~dms/wh-alrgy.html
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TURTLE MOUNTAIN ALLERGEN IDENTIFICATION TABLE: Dairy, tree nuts, peanut, gluten (wheat), and egg

Downloadable PDF Files: COMPLETE LIST | CHOCOLATE FREE | GLUTEN FREE

Printable Allergen Identification Table - (pdf - 17 kb)

*trace is designated as greater than 10 parts per million.

REFERENCES:

1. Food Allergy Initiative. 15 February 2005.
2. Food Allergy Research and Resource Program. 18 January 2005.
3. Food Allergy & Anaphylaxis Network. 18 January 2005.