16 replies to this topic

[Anuhya]

Hi all

 

My friend works for a bakery and they are going for the SQF level 2 audit. He asked me this question. Pls help me.

 

How to segregate raw materials that have different allergens?

 

He has a raw material as an example with peanuts, another raw material with soy, another with gluten and the other with Eggs and milk (all different allergens). Due to the space shortage, he can only stack 3 pallets in a row and 4 columns of each row. How to segregate the raw materials one above the other based on risk?

 

I am guessing that as peanut is a deadly allergen, a raw material with it probably needs to be stacked in the bottom row. But what about the rest? Is there a allergen scale based on impact and risk?

 

Please help!!

[Mr. Incognito]

All allergens have the potential to be a deadly allergen.

 

It is true that typically peanuts cause stronger reactions in people susceptible anyone who is susceptible to an allergen can die from whichever affects them.

 

In such a small setup it is going to be difficult for your friend to be able to adequately protect his products.  It is important for him to use two barrier protection (case and wrap).  Also not to store any allergen over another allergen.  Allergens may only be stored above the same allergen.

[Anuhya]

Thank you Merle. So will it be compliant if he stores the raw materials with different allergens one above the other using two barrier protection? (Because of the Limited space)

[Charles.C]

Thank you Merle. So will it be compliant if he stores the raw materials with different allergens one above the other using two barrier protection? (Because of the Limited space)

 

I have no direct experience this problem but I would suggest it depends on yr opinion as to whether it will be possible to convince an auditor that the risk of cross-contamination during storage / handling is negligible.

 

IMO safest solution from all POV is surely to find more space.

 

I think Merle already rejected yr above proposal but i await his answer with interest !

 

Rgds / Charles.C

[Setanta]

I would also say scheduling can be helpful here.  If you can avoid having all the allergens run at the same time, that would be very helpful.  Running all egg on one day, peanut type products another, etc.  Getting your scheduler to agree may be another thing all together...

 

Storage of allergens should be kept together and in sealed containers.

 

Setanta

[Anuhya]

Thank you Charles and Setanta. I would ask him to conduct a risk analysis based on his stacking and segregation plan. Again Thank you all for such quick replies!

[Egalo]

The frequency of a specific allergen has nothing to do with the impact or consequences a different allergen will have on a person. All allergens can be fatal.

 

It is clear a variety of different allergens become a problem when storage space is reduced. The suggestion of two barriers (plastic and cardboard) is a good one. However, it iwll not pass the FDA inspection and it will probably fail the state inspection as well. What is suggested in this case is that a physical barrier need to be placed between rows or colums. For example, if a column has peanuts and the column next to it has soy, a physical barrier of carboard or wood needs to be place between them. This is a solution recommended by the FDA. Of course, all the allergens need to be labeled and or identified. Hope this help.

 

[Anuhya]

That's really helpful Egalo. Thanks a lot!

[Charles.C]

Dear egalo,

 

Thanks for yr interesting comment.

 

I can believe that FDA represent the gold standard but do you have any knowledge as to whether SQF are egually rigorous ?

 

Rgds / Charles.C

 

PS i seem to recall from a previous thread that bakeries in many US locations do not (luckily?) fall within the scope of FDA

 

PPS Welcome to the forum !

[Tony-C]

The frequency of a specific allergen has nothing to do with the impact or consequences a different allergen will have on a person. All allergens can be fatal.

 

It is clear a variety of different allergens become a problem when storage space is reduced. The suggestion of two barriers (plastic and cardboard) is a good one. However, it iwll not pass the FDA inspection and it will probably fail the state inspection as well. What is suggested in this case is that a physical barrier need to be placed between rows or colums. For example, if a column has peanuts and the column next to it has soy, a physical barrier of carboard or wood needs to be place between them. This is a solution recommended by the FDA. Of course, all the allergens need to be labeled and or identified. Hope this help.

 

 

Thank you for your post Egalo.

 

Please can you post to a link to where the FDA recommends such controls.

 

Regards,

 

Tony

[moskito]

Hi,

 

allergen segregation is possible by separate storage (-> use different definitions)

We have classified the allergens in 3 classes dependent on their "severity" and dosis  (-> see Vital 2 or FDA Threshold Group), which can be helpful in creating a storage plan if space is limited.

We are a bakery. In a first step we have analysed which allergens are present in all our products (e.g. wheat and gluten, milk and egg). This allergen can be excluded from the risk analysis. Than separation can be done by using different rooms or sufficient space between raw material packs. But in some cases separation can be done on time scale, e.g. when special raw materials are used in a special time frame (e.g. seasonal).

If you are using racks, don't store allergens above non-allergen (means without any allergen or another allergen) to avoid cross contact. To avoid cross contact a debagging/deboxing strategy is helpful before entering production/hygiene areas.

Necessary is also a SOP describing the procedure in the case of an accident (e.g. with a fork lifter) to avoid cross contamination of the whole area (e.g. handling, decontamination of environment and clothes etc.).

[Charles.C]

Dear moskito,

 

We have classified the allergens in 3 classes dependent on their "severity" and dosis  (-> see Vital 2 or FDA Threshold Group),

 

This is a rather questionable procedure IMO ?.

I don’t recall the Vital organization, or FDA, suggesting that their data is suitable for such categorisation? Or anybody else ? Some of the theory underpinning the Vital criteria recently seems to have had problems regarding the predicted customer sensitivity to actual materials.

 

Can you validate this classification concept, eg provide a link to any supporting evidence ?

 

Rgds / Charles.C

[john.kukoly]

Admittedly not being a SQF expert, but I doubt that there would be much variance in expectation between most of the rigorous, recognized schemes, I wanted to throw a few thoughts into the mix. Given that there is very limited information about this site, these may be more generic than specific to this issue, but here goes!

 

Issue number 1: artificial boundaries and restrictions that are automatically accepted. Right at the beginning you clearly state, not having enough space to safely manage all the allergens. There are often unique and novel solutions to problems, but one has to keep in mind that there are also times where it is not possible to fix the issue. (In this case, perhaps getting rid of some of the allergens, moving some products to another location, or moving to a location that allows operations to be done safely may be the "right solution".) Bottom line, sometimes a fix is just not possible, and all the alternative interventions simply end up wasting money without getting to the end goal. Allow this as one potential outcome of the risk assessment.

 

Issue number 2: focus on the auditor, and not on food safety. A natural reaction, and I spent enough time on the sharp end of the audit stick to know it can't be avoided at some point, but in the early stage for something truly important to food safety like this, forget about looking for a fix to satisfy the auditor. You need to focus solely on the risk, and how to control or eliminate it. If you do that right (validate where necessary) then the auditor generally becomes a moot point. The only exception is when the audit scheme has a very prescriptive requirement.

 

Issue number 3; focus on the vertical stack. Vertical segregation of allergens during storage is definitely an industry norm, but keep in mind all potential vectors of contamination - handling before and after storage, and airborne contamination, lab sampling, cleaning crews, pallets...

 

For this particular operation, some other thoughts - you can group allergens if it makes sense (i.e. if there is wheat and egg in every product, then you can treat them as a single ingredient) - I think this was what Moskito meant above. As for allowing less rigour on "less dangerous" allergens - really a bad idea, from a regulatory and legal standpoint, it makes no difference that I have ever seen.

[Charles.C]

Dear All,

 

Here are related portions of a couple of typical BRC viewpoints –

Documented procedures to maintain product safety and quality during storage shall be developed on the basis of risk assessment, understood by relevant staff and implemented accordingly. These may include as appropriate:

 

Segregation of products where necessary to avoid cross-contamination (physical, microbiological or allergens) or taint uptake.

etc

 

Or

Documented procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination into products not containing the allergen. This shall include as appropriate:

 

physical or time segregation whilst allergen-containing materials are being stored, processed or packed.

Etc

 

And SQF -

SQF suppliers must identify all allergenic ingredients at receipt, and store them separately from non-allergenic materials, and from materials containing other types of allergens.  Staff involved in  receiving  and  storage  must  be  fully  aware  of  the  presence  and  risk  of  allergens  and  the storage procedure.

All ingredients must be clearly labeled with the name of the allergenic substance, and must be stored and transported to avoid spillage or leakage onto other non-allergenic materials.

 

It is clear that any storage requirements will revolve around interpretations of terms like “segregation” and “separate”.Textually (eg see examples attached) it is IMO implicitly recognised that some deviations to an ideal physical separation are unavoidable in practice. But the magnitude is left unstated (ie risk assessed).

 

Explicit numerical requirements seem to be rare although occasionally occur, eg -

 

Shipping, receiving, handling and storage
Ingredients containing allergens should be shipped in properly labelled and sealed containers, and physically separated from allergen-free ingredients. Receiving employees should inspect the shipments for spills or damaged containers. Allergenic food ingredients should be stored separately from other ingredients. If not possible, a distance of about 1.5 meters should be maintained between allergens and other ingredients. Store allergenic raw materials on the bottom of racks to avoid accidental spills on items below them. Identify raw materials with an “Allergen” and/or a color-coded tag.

 alg0 - storage allergenic material, manitoba.pdf   58.36KB   434 downloads

 

A few random official/non-official viewpoints are listed below –

 

 alg1 - allergen control plan,FARRP.pdf   210.07KB   589 downloads

 alg2 - allergen guide, control list, FSA.pdf   47.7KB   469 downloads

 alg3 - SOP, Allergen Control Program.doc   54KB   676 downloads

 alg4 - allergen control plan, Ontario.pdf   478.05KB   540 downloads

 alg5 - storage allergen control.png   12.14KB   5 downloads

 

Rgds / Charles.C

[L0uis_]

Found this very helpful

Attached Files

•  temp_file_FINAL_Allergen_A4_web1.pdf   3.23MB   310 downloads

Edited by L0uis_, 04 December 2020 - 09:01 AM.

[SJ_LPCR]

I work in a food-grade warehouse. We only ship, receive and store packaged items. When it comes to allergens we receive and store malted barley, rolled oats, and malts made of wheat used for beverage production. I am trying to find if these are considered allergens as far as "storage" of the products in a warehouse.

 

The product we receive does not come with a label that declares it as an allergen. I want to make sure we adhere to SQF Code, so my question is, are we, as a public warehouse responsible for labeling what is received and stored, or is the producer of the product? What steps to I need to take to remain in compliance with SQF and FDA regulations?

 

Also, I am wondering about malted barley and rolled oats; are they an allergen? Our customer that we are storing the product for was surprised by the question about it being a possible allergen. 

Please advise.  

[G M]

I work in a food-grade warehouse. We only ship, receive and store packaged items. When it comes to allergens we receive and store malted barley, rolled oats, and malts made of wheat used for beverage production. I am trying to find if these are considered allergens as far as "storage" of the products in a warehouse.

 

The product we receive does not come with a label that declares it as an allergen. I want to make sure we adhere to SQF Code, so my question is, are we, as a public warehouse responsible for labeling what is received and stored, or is the producer of the product? What steps to I need to take to remain in compliance with SQF and FDA regulations?

 

Also, I am wondering about malted barley and rolled oats; are they an allergen? Our customer that we are storing the product for was surprised by the question about it being a possible allergen. 

Please advise.  

 

It depends on where these items are being used (which legal jurisdiction), but the wheat is the only likely allergen mentioned.  However, both the wheat and barley contain gluten, and for products that will be sold as gluten free it is advisable to treat this with the same kind of segregation techniques.

 

It may be necessary for you to require the exterior of shipping containers to be labeled so you can safety segregate within your facility, especially if it creates a safety conflict between customers.