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Nut management, controls to prevent cross contamination from staff


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#1 Price577874

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Posted 03 January 2018 - 10:36 AM

Hi all,

 

I am Q.A. at a gluten free bakery and we currently produce a handful of products that contain nuts (Flaked almonds + chopped walnuts) as toppings.  We produce and pack a nut containing product last each day to allow for minimal risk and sufficient nut clean downs before next production, we conduct nut swabs on machinery before being reused and have a colour coding system for cleaning equipment and PPE.  My concern is that although staff are wearing their green aprons, hats and over sleeves and working on a specific line they proceed to walk to get a document from a nearby table or push a trolley to the warehouse which in doing so they are passing other packing lines or potentially leaving nut residue on the edge of a table that would be passed to the next staff member who uses it.  BRC audits have not seen any issues with the process as of yet but my question is are there any control methods suitable for the movement of staff members that any of you are currently using? Moveable screens that segregate areas maybe?

 

Any suggestions and comments welcomed.     


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#2 GMO

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Posted 03 January 2018 - 03:09 PM

Hi, and welcome to the forum!

 

Good question and as someone who has a child with a Brazil nut allergy, I'm gladdened to hear people are taking it so seriously and wanting to improve without being pushed.  I think you're right to consider staff movements in your nut risk assessment.  I'm a little unclear if non nut staff are operating at the same time as nut staff as you say it's before a clean down?  So would the tables and other lines not be cleaned at the same time?  In any case one thing which would be really good to do is get a factory plan and draw on it where staff need to move during their shift while they're handling nuts and also draw on it where staff handling non nut products would walk during the same time period.  Even if there are no "non nut" staff, this is still a useful exercise.  That will show you where the cross over points are because as you've rightly indicated, it's not necessarily going to be immediate but it could be someone touching a table or a trolley then another person touching it an hour later.  Once you've done that think about the areas you want to restrict movement.  If they're collecting paperwork, can you move the paperwork closer to them or have it ready in the area it will be used before they start the production run (that's better from an efficiency point of view anyway)?  If the trolley is wrapped product, can a different or dedicated member of staff take it to the warehouse?  Or can the trolley be fully washed after it's been used for the nut products?

 

You've rightly assessed I think that it is going to be difficult in your plant to exclude all traces.  You do need to be aware though that unless you have a very severe allergy, some allergy specialists (including the one I see with my son) tell you not to bother avoiding "may contain" as it's virtually impossible when it comes to nuts.  I have no idea why people put "may contain" nuts but very little other "alibi" labelling when other allergies can be just as severe?  But they do.  In any case, if you had a product which caused an allergic reaction in a consumer and that ingredient wasn't on the ingredient list, you're probably liable under the FIC / FIR in any case despite the "may contains" statement which is almost certainly on your packs.  So it's really great to see you guys taking it seriously.

 

That all said, while cross contamination is a valid risk, the biggest risk is gross contamination and one of the worst is putting the wrong label on the pack so don't forget to make sure those controls are absolutely robust.

 

A last comment and a plea... So many sites control "nuts" as one allergen.  They are not one allergen (if you're allergic to pecans you are probably allergic to walnuts but you needn't be allergic to hazelnuts for example) and nowadays, especially kids are told to eat other nuts to avoid contracting an allergy to them.  So please ensure that as much as you can you control the nuts as separate species if this is possible?  I always say this to people on this forum because unless you have a relative who has been recently diagnosed with a nut allergy you may not be aware of the changed advice from medical practitioners.  It's also really helpful to consumers that if you feel the need to put "may contains" on a pack you specify which nut species may be contained; i.e. in your case walnuts and almonds.  In that case for my son with his brazil nut allergy I know that product is absolutely fine.


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#3 Price577874

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Posted 04 January 2018 - 07:08 AM

Thanks for the reply, The nut containing products are run at the end of each shift, this consists of a depositor that deposits the cake batter and the packing line used to pack the finished product which both have the required nut controls but to help clear your question up there are 3 other packing lines in the packing area that will be running non nut containing products throughout the day which means that even though nut containing products are last on line no4, lines 1,2 +3 will still be running non nut products.  Although they are sufficiently spaced its the crossovers I am concerned about.  I have been discussing with my Technical manager recently who agrees we need to look at the nut risk assessment regarding staff movements and cross over points like you have pointed out, like I said it has not been an issue to date but sometimes when you step back and take a look at current processes in your related fields you sometimes see things that can be improved or 'tidied up'.  I think staff awareness may also be a factor in this as although all staff are fully trained on the nut control procedures they do not always see the bigger picture, if they were to quickly go and ask a question to an operator in the weigh up area and pass through a strip curtain which rubs against their apron and picks up residue that could be passed to the next person.  As you have said I think the risk is minimal but never the less I think it would be good practice to reduce these potential issues if indeed possible.        


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#4 GMO

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Posted 04 January 2018 - 08:14 AM

I absolutely think you're approaching this in the right way.  Yes I'd definitely map out staff movements.  This wasn't for nut control but in one factory I saw really good "zoning" where people operated within that zone only.  They literally marked out the zone on the floor.  I'm not sure if that would work for you?  I'm always worried by screens as they can become a source of contamination in themselves. 

 

I think what I'd do if you can is stand and watch during nut production for a few production runs and see where people go and what they do.  Alternatively set up a camera if you can (a cheap webcam may do the job).  That will get you "real life" of what is actually happening.  Put it on a plan and save key bits of video to explain with your plan to your staff during training later.  I'd also then use it as a SMED exercise I suppose.  SMED is normally used for improving efficiency but you can use it here I think to reduce risks of cross contamination (and also probably improve efficiency) by reducing those unnecessary staff movements which are potentially increasing risk to your non nut products.  I did this one time with a cleaning process to both try and improve cleaning and reduce inefficiency.  It was hilarious!  Machine got wheeled into the wash room.  Guy stops, scratches his head then goes to a locker about 300m away to find the tools to dismantle the machine which is only ever dismantled in the wash room.  Action one, tools moved to the wash room.  Then he started to dismantle but didn't have somewhere to put the parts so went to find a trolley not designed for the purpose which was a struggle to fit the parts on.  Action two, specific trolley was made and stored in the wash room.  Do you get what I mean?

 

Of course the "gold standard" would be eventually to segregate completely.  I have to admit a personal frustration to seeing items in the "free from" category in a supermarket which say "may contain" on them and I'm sure there will be a retailer drive for this in the future to not have "may contain" on items intended for allergenic customers.  After all, your gluten free customers may also need to avoid nuts.


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#5 Price577874

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Posted 04 January 2018 - 10:28 AM

I do totally agree about the screens as we do have 1 wash screen for clean downs and it does cause a variety of issues from time to time,  Thanks for the useful suggestions, I will definitely be observing a few production runs to establish the most frequent crossover areas and implement some changes to prevent this and as you have said this will assist in efficiency levels.  It is also very interesting hearing how this has worked with yourself and how we all have these small issues that we do not know exist but once discovered are easily solved with some simple changes.


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