Week 5 Contamination & Cross Contamination Prevention - Allergens
• Allergens
Allergens is one of my favourite topics and is a very important one. It’s vital to know how to control allergens from raw materials, through storage, to production and labelling. I’m going to explain everything. If there is anything you would like to chat through, please do not hesitate to let me know and we can arrange a call. My contact details are at the bottom of the attached document.
What’s coming next….
Week 6 Glass & Hard Plastic, Metal Control – including metal detection
Week 7 Wood Control, Chemical contamination prevention
Allergens – what do you need to show your SALSA auditor?
What you need:
• Allergen Control Procedure – this can be part of your Contamination & Cross Contamination Procedure and can also include your allergen policy – what you DO NOT PERMIT on site in staff lunches or from visitors or contractors.
• Allergen Risk Assessment
• Allergen Labelling on Pack
• Allergen Swabbing Regime (if required)
• Allergen Training – if this is a separate training document do not forget to include the details from your allergen policy – what you DO NOT PERMIT on site in staff lunches or from visitors or contractors.
Where do you start?
You need to know your 14 allergens…!
1. Cereals containing gluten: (wheat, rye, barley, oats, spelt, khorasan wheat and their hybridised strains),
2. Crustaceans
3. Molluscs
4. Fish,
5. Egg
6. Milk
7. Soya
8. Peanuts
9. Tree nuts: (almond, hazelnut, walnut, cashew, pecan, brazil, pistachio, macadamia and Queensland nuts),
10. Celery
11. Mustard
12. Sesame seed
13. Lupin
14. Sulphur dioxide and sulphites, (and products derived from these).
You need to know where to find them in the ingredients you are using.
At the beginning, you need to know what allergens you are bringing onto your site in the raw materials you use. This means you need to attain all of the raw material specifications from your suppliers for the ingredients you are using.
Do not assume you know all of the allergens in the raw materials. Sometimes you might be surprised at what allergens are in your ingredients. Don’t leave it to chance – use the specifications.
Ingredients list with allergens contained
Have a list of all of your ingredients documented, then from the specifications, list the allergens included within the raw materials. This is also part of Control of Raw Materials so needs to be done anyway, however it’s very important to know at the outset that you need the raw material specifications as soon as you start getting ingredients.
This allergen list can be the first stage towards producing your allergen risk assessment.
What about allergens that ‘may’ be contained?
You may find that on the specifications you receive, that they may also have a ‘may contain’ or ‘handled in the facility’ for other allergens which they handle on the supplying site. These allergens also need to be considered, but before you put them on your allergens list, you need to ask some questions of your supplier to determine if it is necessary or not.
You need to know if these allergens are likely to be in the ingredients or not, therefore ask the following:
• Are the allergens handled on site, but not actually opened (still packaged)?
• Have they done allergen testing on the ingredient and it has a positive result?
• Are allergens handled on the same line as the ingredient being supplied?
• Are allergens handled in the same area / room that your ingredient is being produced?
• What is the allergen status, such as a powder (which is more likely to contaminate) or a liquid or in solid form?
• Do they complete allergen swabbing of the equipment, line, surfaces?
• What are the results of the swabbing?
Consider what these answers mean to your product.
For example, if another allergen is handled on the same equipment as the ingredient supplied to you, this is the point where it could have caused cross contamination. If the supplier has then completed swabbing validations on the equipment, and they were positive, that is why they have to put the ‘may contain’ on their specification. This means you will have to consider putting the ‘may contain’ allergen on your finished product too, unless you do some testing to evidence it is not present.
If they have put ‘may contain’ and have not carried out swabbing or product testing for the allergen on the line, then you can either ask the supplier to complete the swabbing, (which usually comes at an additional cost), or you may have to test the raw material yourself if you do not want to list it on your pack. Otherwise, you have to list it on your pack.
If the allergens are fully packaged on their site and not opened, then the risk is very low so probable you do not need to list them on your finished product.
All of the ‘may contain’ allergens should be based on a documented risk assessment. This needs to show your logic and rationale for deciding to take them forward as allergens which require including on your finished product Allergen risk assessment. And reasons for why they don’t.
Allergens is a complex subject and one we need to get 100% right, so if you want to chat anything through, you know where I am! And it is my favourite subject!!
Finished Product Allergen Risk Assessment
Stage two of your allergen risk assessment can then be, making a list of all of the finished products recipes, detailing the raw materials in them, then transferring the allergens contained within the raw materials from your allergen list to build up a picture of your allergens contained in each recipe.
When you have completed this, it will show you the allergens you need to state on the back of your pack for each finished product.
This is the document you will use to cross check that you have got all of the finished product labelling correct when you produce your product labelling artwork.
You DO need to consider what allergens are sharing equipment on your site, in case cross contamination occurs from one product to another, as if you have some products with sesame in, and some without, but they share the same equipment, you need to be able to guarantee they do not cross contaminate, by swabbing equipment, or labelling both with sesame.
Please read on for how to tackle cross contamination…
Allergen Cross Contamination
Now, if we have successfully completed all of the above, we know what allergens are in our factory. We need to know what areas of the factory they are going to be in, from the point of storage, through production, packing to dispatch. The reason is, we need to control cross contamination of other non-allergen containing products. Even if you are putting ‘may contain’ on the label, it still needs to be controlled as much as possible.
Last week, we spoke about having a site plan with all of the routes documented on it – allergens being one of them. This is the reason why. We can also use the process flow diagram to help us understand where allergens will be present. You need to make sure the allergen risks/hazards are identified in your HACCP plan at the cross-contamination points of the process.
Allergen Controls
The type of controls for handling allergens, will depend on the number of allergens you handle, and how segregated you need to keep them. For example, there might be a nut product which you want to keep totally segregated, or you might have a gluten free product range in a gluten containing bakery.
Controls we are going to talk about are, storage, colour coding, segregated areas, production planning, equipment, swabbing and labelling.
Allergen storage
• Allergens need to be stored in a segregated area of your warehouse or store room.
• The allergen shelving needs to be labelled up with the specific allergen being stored there which should not change.
• Allergens should be stored on low level shelving, so if there are any spills, they do not spill onto the ingredients below them, therefore contaminating them.
Allergen colour coding
To control allergens, you might decide to go down the route of having colour coded containers and utensils. You might also decide it is a good idea for the staff members to have different colour uniforms to handle allergens which get laundered separately, or colour coded disposable aprons and sleeves.
Segregated allergen handling areas
Having separate areas or rooms to handle allergens is a great idea, and if your site can facilitate this, then it is suggested. However, this is not always possible, so using time segregation and production planning is another option.
Separate equipment for handling allergens
If you can have separate equipment for specific recipes with allergens, such as cooking vessels, mixers, depositors, food contact packing lines/belts, filling machines etc, that is best practice. However, this is not always practical, so using production planning and robust, validated cleaning regime is essential.
Production Planning
Production planning, just means planning the production of products which do not contain allergens first, through to the products which contain more allergens. Have specific times set out for when an ‘allergen clean’ is required so the staff have the time to carry this out effectively. Full allergen clean downs are essential at the end of the day.
Allergen Swabbing
You will have to validate your allergen cleaning regime by carrying out swabbing to ensure you have removed all traces of allergens. Cleaning validations can be done with your chemical company if they provide this service. You need to decide the chemicals and methods, then carrying out swabbing before and after the cleans to prove your chemicals and methods work. If not, adjust them accordingly, then try the swabbing again until you get it right. Document your validations. Always use specific allergen swabs as they have a lower limit of detection and are looking for a specific allergen.
You will also have to do routine allergen swabbing on a set frequency, to prove the cleans are continuing to work – as a verification.
Make sure all cleaning is recorded and verified, that it has been cleaned to the correct standard, and that the swabbing has been completed, and results are acceptable prior to moving on to the production of the next product.
Any assistance with setting up swabbing regimes, please do not hesitate to contact me for help!
Sometimes, depending on the type of equipment you are using, it might not be possible to remove all traces of an allergen, due to the intricate parts, which is where it is necessary to add the allergen to your product labelling.
Allergen Labelling
All allergens within the ingredients must be stated on the product label. You have to label them in bold highlighted font.
You have to have allergen signposting how to define the allergens in the ingredient declaration.
All allergens which are a cross contamination risk in your process which cannot be removed, must be put on your product labelling. This is where you can put a statement such as ‘may contain’ or ‘made in a facility which also handles’ or ‘not suitable for someone with X allergy’.
All allergens which are a risk from your suppliers’ site, which have a risk that cannot be removed, must be put on the product label. Unless you have done some testing which proves they are not in the raw material.
Other Essential Allergen Controls on Site
Allergen spillage controls – have a procedure which states exactly what to do for allergen spillages.
Have a section of your Personal Hygiene Procedure which states which allergens are not permitted to be brought onto your site for staff members, visitors and contractors.
Ensure if you have vending machines or caterers making lunches for meetings, they do not serve any of your non-permitted allergens.
Packing and labelling controls – having the right label or pack for the right product at the line at the time of packing. Sounds quite simple, but it is one of the main reasons for recall in the UK - packing the product into the incorrectly labelled pack, with the wrong allergen declaration on it!
We will go into labelling and packing controls in more detail when we get to that section.
Allergen training – All staff members should have basic allergen awareness training which should include what all 14 allergens are and what allergens you have on your site and allergen spillage training.
Over and above this, having and any task specific allergen training such as allergen segregation in storage, allergen clean downs, allergen swabbing, allergen labelling etc. is so important.
Remember all training should be signed off!
I told you allergens was a big topic, and there might be more questions, so please let me know I am here to help!
On that note, that is the end of this section. Please do not hesitate to ask any questions.
Be careful and stay safe!
Ruth
Ruthshawconsultingltd@gmail.com
07732 966 836
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