16 replies to this topic

[Bojan]

Greetings all,

i have order of large quantities of one of ours products (vanilla fill).
Catch is, it has to have nut free label.

As you can guess, we dont have it.
So my question is, how to get it?

In my production i have walnuts and hazelnuts.
All my products are declared "may contain".
So, do i need to separate specific production in different machines, different rooms etc?
All raw material to be also declared nut free?

Country in which i will export (if lucky) is UK.

I spent all morning in search function here, but i am unlucky, or blind :)

Thank you in advance.



Bojan

[Tony-C]

Hi Bojan

You will need to have appropriate controls for segregation. Examples extracted from a Nut Control Operational Prerequiste Programme:

Raw Material Intake
Any product containing nuts and nut derivatives must be isolated from the "nut free" stock, by placing the product in the nut products area on receipt.
On receipt of an order from the Factory for nut materials, the materials will be identified on the dispatch note and identified on the vehicle.
The products which contain nuts currently are..................................
The materials will then be moved into the locked nut section in the store which is separated by a metal fence and identified by notices.

Production
All nut materials are identified by a label, stating the product name. There will be no part bags used.
Any material remaining at the end of production will be disposed of into the skip.
Segregation where possible will be achieved by a dedicated line for nut products.
If this is not possible nut products will be produced last and followed by a full clean which is signed off by the Shift Manager/ Senior Shift Manager in the Factory.
Production orders versus product produced and raw materials stocks will be reconciled and signed off.
When there is more than one Nut Product produced on a filling machine, then the potential risk will be assessed and the product filled in assessed order e.g. almonds precede peanuts.

Development Trials
If there is a Development trial on production equipment, the samples must be fully assessed and nut products or by products will fall into the "produced last, full clean after" ruling.

Packaging
It is potentially as dangerous to mix nut packaging with non nut packaging.
All nut packaging will be kept in the designated locked areas which is additionally identified by red lines on the floor and walls.
All nut packaging must be returned to that area once production has finished. Only the Shift Manager and Senior Shift Managers will have keys to this area.
On no account must any nut free packaging be placed in the nut designated area
All nut packaging must be clearly marked by a prominent label and packed into inner bags will be sealed must be coloured red.
If there is packaging which could be confused with a nut product then this will be treated in a similar way and will be packed in sealed blue bags.

Production Planning
Where possible non nut products which have a similar appearance with a nut product are not run sequentially to prevent confusion with the ingredients and the packaging.
They are separated by time and dissimilar products. This will be done at the planning stage.

Production Operation
To identify nut production run operatives on the machine will wear red mop caps.
This serves two purposes:
- To identify that only authorised personnel are working on the machine.
- It highlights the difference of the running operation to the staff.

Hope this gives you some sort of idea of the controls you need. You have a lot of work on your hands.

Good Luck.

Tony

[Bojan]

Tony,

thank you for fast and detailed response.

Lot of work, you are right :)


Bojan

[GMO]

I would go further. If you actually want to claim "nut free" and not "may contain", I think you have to have a separate production area. If you are processing nut products on the same line, the risks are there. Note, that the biggest risk especially if you are sleeving or labelling is actually mislabelling the product so control of the packaging and having separate areas makes that easier.

I'd also have a "nut spillage procedure" for any areas which do have to be dual purpose (e.g. intake).

In the UK, very few factories would approach making a nut free product without a separate factory or at least a separate area with dedicated controls. If you go down the route of just cleaning down between products, you have to accept there will always be a risk of a recall and losing all of your business. Not one I'd be willing to take!

[Tony-C]

I would go further. If you actually want to claim "nut free" and not "may contain", I think you have to have a separate production area.

I agree this is the best option but not always practical. I would use a separate line as a minimum. At the end of the day any risks must be assessed.

Regards,

Tony

[GMO]

I agree this is the best option but not always practical. I would use a separate line as a minimum. At the end of the day any risks must be assessed.

Regards,

Tony

I can't imagine any retailers being happy with anything less than this if it was own brand. It's a very scary proposition to take the risk of running alongside products which you are claiming are nut free and contain nuts. Tesco are very clear about how products should be labelled. For these kind of controls they would specify that you need to put something along the lines of "recipe; contains no nuts, factory and equipment also used for processing nuts" or something like that. I can't remember the exact wording!

[Bojan]

Well, it was much simpler when i didnt have all this information :)

Anyway, im still trying to find can i get main raw material with "no nut" label.
Without that, all my trouble is for nothing :)

Thank You both for quick and detailed responses.

I will keep you informed.




Bojan

[Tony-C]

I can't imagine any retailers being happy with anything less than this if it was own brand. It's a very scary proposition to take the risk of running alongside products which you are claiming are nut free and contain nuts. Tesco are very clear about how products should be labelled. For these kind of controls they would specify that you need to put something along the lines of "recipe; contains no nuts, factory and equipment also used for processing nuts" or something like that. I can't remember the exact wording!

I assume you meant factory and equipment not used for nut processing.

UK Retailers vary. If you handle nuts in your factory then Morrisons mark "Contains nuts" on their packaging whether the product does or not.

A useful link and summary of Retailer policies with regards to nut labelling here:

http://www.nonuts.co...upermarkets.htm

Regards,

Tony

[GMO]

Lol! Sorry we haven't made it easier. Actually saying "nut free" on UK products is a really emotive issue. I believe nut allergies are way more common in the UK than in mainland Europe, whereas celery allergies are very uncommon here but more common in continental Europe.

I've always wondered why that was. It must surely be to do with diet but considering most processed products in the UK now try to be nut free, nut consumption in the UK must have fallen.

[Charles.C]

Dear GMO,.

I've always wondered why that was.

It's slightly OT but perhaps the typical UK inhabitant is genetically predisposed to "nutty" characteristics. Many examples spring to mind, eg 5-day Test Matches, the weather. The Vikings are probably to blame.

Rgds / Charles.C

[Bojan]

From nut free label to Vikings...

Didnt saw that coming.

[Tony-C]

From nut free label to Vikings...

Didnt saw that coming.

We didn't see the Vikings coming either until it was too late!

[Charles.C]

Dear Bojan,

The fact is that you are, I suspect, attempting to enter into a high risk product area in respect to both the emotive and potential side-effects as GMO noted. The labelling aspect (or appropriate lack of) is the (overall) No.1 cause of recalls in UK from memory. But I'm sure you know this already.

Hazelnut also seems to be a particularly difficult item just like peanuts, eg

Peanut (Arachis hypogea) and hazelnut (Corylus avellana) are notorious for causing allergic reactions in childhood. (1) After exposure of allergic children to the culprit peanut or hazelnut, the first symptoms of an allergic reaction usually occur within one hour.
(2) Symptoms can occur

http://igitur-archiv...01006/index.htm
(see chapter 1)(some UK data is included within the very heavy technical content)

Rgds / Charles.C

[Techy4580]

Kind of an off side question here......

Several of our factories declare themselves a 'nut free' site which is something I have difficulty in accepting. They have a nut policy that states that no nuts may be brought onto site thus maintaining the nut free status. My question is how do you enforce and audit this??

If you have a policy which states nut free you must be able to demonstrate compliance to this - so how do you go about this?? Should we be checking the lunchboxes of our work force to ensure that no nuts are included?? It maybe easy to spot a bag of peanuts in a lunchbox but if they are bringing say a home-made curry to heat up at lunchtime how do we know that it is nut free.

I know the arguement would be that we educate and train staff so that they know that nuts are not allowed on site but how many of the workers would mention this to a wife/husband who may pack their lunch for them??

How can we ensure a nut free site?? IMO we cant which is why I favour the nut free factory status.

Anyone else got any views on this??

[Tony-C]

Kind of an off side question here......

Several of our factories declare themselves a 'nut free' site which is something I have difficulty in accepting. They have a nut policy that states that no nuts may be brought onto site thus maintaining the nut free status. My question is how do you enforce and audit this??

If you have a policy which states nut free you must be able to demonstrate compliance to this - so how do you go about this?? Should we be checking the lunchboxes of our work force to ensure that no nuts are included?? It maybe easy to spot a bag of peanuts in a lunchbox but if they are bringing say a home-made curry to heat up at lunchtime how do we know that it is nut free.

I know the arguement would be that we educate and train staff so that they know that nuts are not allowed on site but how many of the workers would mention this to a wife/husband who may pack their lunch for them??

How can we ensure a nut free site?? IMO we cant which is why I favour the nut free factory status.

Anyone else got any views on this??

You train your staff in the types of foods that contain nuts and you ask them to sign a declaration that they won't bring food containing nuts on site. You audit these requirements and check what staff eat in the canteen periodically.

From a risk prospective if you do this what is the difference between a nut free site and a nut free factory?

Regards,

Tony

[Janice Galvez]

Hi,
Currently we are trying to go to a Peanut Free production. We initially thought that not producing peanut products was going to be sufficient. We are now at the point where we are elliminating suppliers of our raw materials because they can not gaurantee us they are peanut free. I initially joined this site looking for an audit to do for the lunchrooms, etc. to ensure there are no peanuts. Now I am investigating testing for products, not just the lines, to be able to declare particular products are peanut free. If anyone has any suggestions or helpful hints I would very much appreciate them. Thanks.
Janice

[cosmo]

Hi,
Currently we are trying to go to a Peanut Free production. We initially thought that not producing peanut products was going to be sufficient. We are now at the point where we are elliminating suppliers of our raw materials because they can not gaurantee us they are peanut free. I initially joined this site looking for an audit to do for the lunchrooms, etc. to ensure there are no peanuts. Now I am investigating testing for products, not just the lines, to be able to declare particular products are peanut free. If anyone has any suggestions or helpful hints I would very much appreciate them. Thanks.
Janice

Hi Janice
We are a totally gluten and nut free site. To validate these claims we do a number of tests and have certain procedures that enable us to measure and quantify the levels of contamination.
First some of the tools we use are from the allergen website. This sites downloads are available with the registration of your name and email (so you can receive the updates)

http://www.allergenbureau.net/
http://www.allergenbureau.net/vital/

The vital (Voluntary Incident Trace Allergen Labeling) system has a series of exercises where you calculate (spread sheet)cross contaminants and the result indicates which level of labeling you require on each product. This will indicate if you require "contains" or "may contain" statements on your packaging.

Although this is Voluntary, Woolworths Require it (compulsory) if you wish to pass a WQA audit.
As far as our ingredients go, we screen incoming batches using a rapid 3D test for Gluten, peanut, almond and hazelnut.
Our finished product testing also includes an ELISA test for gluten and peanut. These give a ppm number.
In order to validate nil cross contamination from nuts we swab the lunch room door handle (has picked up traces) and as such have requested no nuts be brought in via lunches. We have not picked up traces since this request.

This testing is not only done on ingredients and finished product, but also swabs of process surfaces, ingredients packaging and occasionally employee hands after the hand wash station.

This is by no means the full extent of our program, but I trust this will help with some direction for your nut free status.