Hi Casper13,
An interesting question. First of all I'm assuming that you are not making any allergen claims.
In order to decide what training is required you will need to consider the potential for allergen contamination, this will include
- cross contamination of raw materials at suppliers
- allergen status of maintenance materials such as lubricating oil
- potential contamination from bought in food or from catering facilities
BRC Standard 4.8 STAFF FACILITIES
4.8.10 Where catering facilities are provided on the premises, they shall be suitably controlled to prevent contamination of products (e.g. as a source of food poisoning or introduction of allergenic material to the site).
Interpretation
In some operations (e.g. sites manufacturing a product with an allergen claim), specific allergens present a particular risk. These sites should specify any relevant company policies to confectionery vending suppliers and catering facilities (e.g. a ‘no nut policy’ on the site due to the manufacture of ‘nut-free’ products).
BRC Standard 5.3 MANAGEMENT OF ALLERGENS
5.3.1 The site shall carry out an assessment of raw materials to establish the presence and likelihood of contamination by allergens
Interpretation Raw material assessment
Raw materials are a potential source of allergens and of cross-contamination. Therefore, the supplier approval and raw material risk assessment procedures (clause 3.5.1) must include an assessment of raw materials for the presence of allergens and the potential for cross-contamination.
Raw material specifications (including flavourings, additives, carriers and processing aids) must be agreed with each raw material supplier and include the allergen status (both content and risk of cross-contamination) of the materials.
BRC Standard 5.3 MANAGEMENT OF ALLERGENS
5.3.4 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:
• restrictions on food brought onto site by staff, visitors, contractors and for catering purposes.
Interpretation:
The allergens that may be handled in non-production areas of the site – for example in canteens or in new product development. A policy for food brought onto site by staf, or used in vending machines or catering facilities, should be developed. The policy may ban certain allergens or restrict them to certain areas of the site.
BRC Standard 7.4 PROTECTIVE CLOTHING
7.4.1Interpretation Documented protective clothing policy
The company is required to determine the procedures for application and use of protective clothing, based on a risk assessment. The risk assessment must consider foreign-body, microbiological and allergen risks as appropriate, as well as general good practice principles. It must document:
• procedures for canteens and smoking areas
So on to training, if you have decided there are no risks from raw materials there is general training to make staff aware of key allergens and any restrictions you applying in staff bringing them on site, where they are stored and where they are to be consumed. There is also the control of catering facilities, to consider so what allergens are being handled there and what controls you are going to apply such as the removal of protective clothing and hand washing.
Your rules can be covered in induction training:
BRC standard 7.1 TRAINING
7.1.1 Interpretation Initial training and supervision
The following may be considered:
• induction training for all staff, covering company policies on hygiene, allergens, quality requirements, a basic introduction to HACCP etc.
Engineers may need to be also aware of allergens in maintenance chemicals and technical staff who are scrutinising raw materials more in depth training:
BRC standard 7.1 TRAINING
7.1.4 All relevant personnel, including engineers, agency-supplied staff and temporary staff and contractors, shall have received general allergen awareness training and be trained in the site’s allergen-handling procedures.
Interpretation Allergen training
All personnel (including all agency-supplied and temporary staff, and contractors) involved in handling ingredients, equipment, utensils, packaging and products must receive training to raise awareness of food allergens and the specific allergen measures used by the company.
The level of training should be appropriate to the individual’s role. For example, junior staff may require only a general understanding of the importance of allergens (information that could be included as part of the induction process), plus any specific procedures in which they are involved. However, the technical team will require greater detail.
Training records must be kept.
Kind regards,
Tony
that's why I'm doing everything I can to not disappoint the management).
