6 replies to this topic

[GMO]

I asked for some advice from BRC on the following (copied from my original mail):

Section 5.2.8 - equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross contamination by allergens. The cleaning methods shall be validated. How can I validate this in a bakery? We can't use general all purpose "allergen" swabs because we are a bakery and so all of our products contain wheat and gluten. We also cannot have a dedicated set of mixers, trays or a dedicated oven. Much of our equipment is not designed to be wet cleaned (as it isn't in any bakery because otherwise it would damage the surface causing a foreign body issue.) I'd welcome any ideas!

This is the response:

5.2.8 – This clause is applicable to those products that do not contain an allergen or where an allergen is used intermittently. For example, if you were making gluten free bread having been making bread containing gluten, then you would need to clean down equipment. Alternatively if you were using egg or milk in any of the products then you would also need to perform a full clean in order to ensure that no proteinaceous materials were present.

So he's completely ignored my question for one which was "how" and completely tried to kill the UK baking industry. This means every time we use an improver containing a very small percentage of egg, milk or soya and then move to a product which does not contain any of these allergens, I have to do a FULL CLEAN, yes, you read it right, A FULL CLEAN before changing over.

So presumably I need to ensure the mixers, dividers, moulders, trays, ovens... That's about 3 hours work between each batch. Now, hang on, some of these items can only be dry cleaned! Oh joy! Also what about the risk of using wet cleaning with open product nearby? I would argue there is a tiny risk of carry over of an allergen from simply clearing down the machine (we don't use nuts or sesame btw) but a huge risk of chemical contamination if they get out the cleaning stuff!

I've been very pro BRC in the past but this stuff is just ridiculous. Don't get me started on the idiotic response on my questions on chiller monitoring.

Edited by GMO, 09 January 2012 - 12:16 PM.

[cazyncymru]

I asked for some advice from BRC on the following (copied from my original mail):

Section 5.2.8 - equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross contamination by allergens. The cleaning methods shall be validated. How can I validate this in a bakery? We can't use general all purpose "allergen" swabs because we are a bakery and so all of our products contain wheat and gluten. We also cannot have a dedicated set of mixers, trays or a dedicated oven. Much of our equipment is not designed to be wet cleaned (as it isn't in any bakery because otherwise it would damage the surface causing a foreign body issue.) I'd welcome any ideas!

This is the response:

5.2.8 – This clause is applicable to those products that do not contain an allergen or where an allergen is used intermittently. For example, if you were making gluten free bread having been making bread containing gluten, then you would need to clean down equipment. Alternatively if you were using egg or milk in any of the products then you would also need to perform a full clean in order to ensure that no proteinaceous materials were present.

So he's completely ignored my question for one which was "how" and completely tried to kill the UK baking industry. This means every time we use an improver containing a very small percentage of egg, milk or soya and then move to a product which does not contain any of these allergens, I have to do a FULL CLEAN, yes, you read it right, A FULL CLEAN before changing over.

So presumably I need to ensure the mixers, dividers, moulders, trays, ovens... That's about 3 hours work between each batch. Now, hang on, some of these items can only be dry cleaned! Oh joy! Also what about the risk of using wet cleaning with open product nearby? I would argue there is a tiny risk of carry over of an allergen from simply clearing down the machine (we don't use nuts or sesame btw) but a huge risk of chemical contamination if they get out the cleaning stuff!

I've been very pro BRC in the past but this stuff is just ridiculous. Don't get me started on the idiotic response on my questions on chiller monitoring.

I think the whole allergen debate has gone completely mad!! We don't realistically have criteria to follow for the majority of them!! But lo and behold, if there's a bandwagon to get on, then their ALL on it!

We have spent an absolute fortune on allergen testing. I don't even want to think about what we've spend, but we can probably bail out a eurozone country!!

We're in a similar position to you GMO. Only, i can use water! but it adds hours onto our day. We have risk assessed to infinity and beyond. Nothing moves in our factory without it having been risk assessed. Our production plan has been risk assessed and reissued so that we can "manage" allergenic products in a "safer" manner. We have been audited by everyone and their dog. And still they want more!!

God i hate food!!

Caz x

[Madam A. D-tor]

Dear Ladies,

So he's completely ignored my question for one which was "how" and completely tried to kill the UK baking industry. This means every time we use an improver containing a very small percentage of egg, milk or soya and then move to a product which does not contain any of these allergens, I have to do a FULL CLEAN, yes, you read it right, A FULL CLEAN before changing over.
So presumably I need to ensure the mixers, dividers, moulders, trays, ovens... That's about 3 hours work between each batch.

We're in a similar position to you GMO. Only, i can use water! but it adds hours onto our day. We have risk assessed to infinity and beyond. Nothing moves in our factory without it having been risk assessed. Our production plan has been risk assessed and reissued so that we can "manage" allergenic products in a "safer" manner. We have been audited by everyone and their dog. And still they want more!!

I do not read in requirement 5.2.8 that you should clean after every iny-tiny allergen concentrated product.

Equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination by allergens.

I read this as:
IF you have equipment or area cleaning, THEN this shall be designed to remove or reduce to...etc.
Risk assessment will tell you if this cleaning is needed between different recipes/products.

The cleaning methods shall be validated to ensure they are effective and the effectiveness of the procedure routinely verified.

How can I validate this in a bakery? We can't use general all purpose "allergen" swabs because we are a bakery and so all of our products contain wheat and gluten. We also cannot have a dedicated set of mixers, trays or a dedicated oven. Much of our equipment is not designed to be wet cleaned (as it isn't in any bakery because otherwise it would damage the surface causing a foreign body issue.) I'd welcome any ideas!

This validation was also required in issue 5 of the standard. (req 5.2.1.6). I am sure that you both, do already have a validation of your allergen cleaning methods.
GMO, what is beside the gluten and wheat your most important allergen?
The verification part is new. We recently discussed this with a group of Dutch auditors. I myself think that you should verify by allergen testing on a regular base. Frequency will be depending on the size of the site and the allergens concerned, but I will be happy with allergen tests for verification every 6 months. There was one auditor, stating that visual verification (colour) could also be possible for some products, but I do not believe that spores of allergens will be visible.

Cleaning equipment used to clean allergenic materials shall either be identifiable and specific for allergen use, single use, or effectively cleaned after use.

This is totally new and I think it is good. However, if you have several different allergens on site, how many specific allergen coded cleaning materials will you need? colour coding? How many colours are there in the rainbow?

Edited by Madam A. D-tor, 09 January 2012 - 06:39 PM.

[immortal]

The standards are very general and not specific to any kind of food so it makes everything get mad with every new revision. There should be different standards for each food type or at least should be some gmp documents should be attached to the standards. What do you think?

[GMO]

Dear Ladies,



I do not read in requirement 5.2.8 that you should clean after every iny-tiny allergen concentrated product.


I read this as:
IF you have equipment or area cleaning, THEN this shall be designed to remove or reduce to...etc.
Risk assessment will tell you if this cleaning is needed between different recipes/products.



This validation was also required in issue 5 of the standard. (req 5.2.1.6). I am sure that you both, do already have a validation of your allergen cleaning methods.
GMO, what is beside the gluten and wheat your most important allergen?
The verification part is new. We recently discussed this with a group of Dutch auditors. I myself think that you should verify by allergen testing on a regular base. Frequency will be depending on the size of the site and the allergens concerned, but I will be happy with allergen tests for verification every 6 months. There was one auditor, stating that visual verification (colour) could also be possible for some products, but I do not believe that spores of allergens will be visible.


This is totally new and I think it is good. However, if you have several different allergens on site, how many specific allergen coded cleaning materials will you need? colour coding? How many colours are there in the rainbow?

Thanks for your voice of pragmatism as ever! Our validation of cleaning procedures is frankly poor but more based upon micro (which again is basically not an issue in bread) but I've bought some allergen swabs at £90 per allergen type.

Our other allergens on site (apart from wheat and gluten which is in everything) are soya, milk and egg.

[Madam A. D-tor]

Dear GMO,

Well, it is a good thing that you will validate your system.

It is hard to find the most critical place to swab.
You do not need allergen tests for allergens you do not have on site.
Make sure you do the validation after the product with the highest concentrate allergenic materials (worst case).

I have no experience in bakeries, but in a lot of other industries it is also possible, sometimes even better to test the first products of the allergen free recipe after the allergen containing recipe and ofcourse after the cleaning. Especially when pipes and valves are included. e.g. with sauce production, meal production, etc.
Allergen containing recipe- cleaning - non-allergen containing recipe. Take a sample of the first products from the second recipe and analyse this for the relevant allergens. I have also seen procedures were the first x packages after cleaning were destructed, because it has been validated that the xth product does not contain any allergenic materials anymore.
sometimes the last rinse water is checked for allergen containing materials. Maybe some one on this forum, has any experience with this.

Succes with your validation.

[fredslule]

Dear GMO,

Well, it is a good thing that you will validate your system.

It is hard to find the most critical place to swab.
You do not need allergen tests for allergens you do not have on site.
Make sure you do the validation after the product with the highest concentrate allergenic materials (worst case).

I have no experience in bakeries, but in a lot of other industries it is also possible, sometimes even better to test the first products of the allergen free recipe after the allergen containing recipe and ofcourse after the cleaning. Especially when pipes and valves are included. e.g. with sauce production, meal production, etc.
Allergen containing recipe- cleaning - non-allergen containing recipe. Take a sample of the first products from the second recipe and analyse this for the relevant allergens. I have also seen procedures were the first x packages after cleaning were destructed, because it has been validated that the xth product does not contain any allergenic materials anymore.
sometimes the last rinse water is checked for allergen containing materials. Maybe some one on this forum, has any experience with this.

Succes with your validation.

In small artisan bakeries where several products are made but with more than one allergen in the processing fascility, does testing for allergen presence after one run if found to be absent when you make produscts in the next run imply that u can skip testing for allergen testing when u make subsquent cleaning after running an allergen and changing product?. Is verification specific per run or can be done after a period like every 3 months ?