4 replies to this topic

[Techy4580]

Hi

I work for a large chilled product manufacturer operating numerous sites both in the UK and overseas.

We supply all the main UK retailers which include M&S. As a large group we have our own codes of practices which we employ across all our sites including an allergen management standard. This standard include allergen matrix, process matrix and a comprehensive risk assessment - however the format of the risk assessment is not entirely in line with th M&S allergen COP. Although our format is slightly different we do come to the same conclusions and at the end of the day allergen controls will be identical regardless of the format of the risk assessment. IMO our risk assessment is far more in depth than the M&S verion

I am finding that during M&S hygiene/PPC audits there are huge discrepancies between how the auditors view the allergen management systems in place on site.

Some M&S auditors are happy with our risk assessment as long as the M&S technologist has signed off against the risk assessment.

Other auditors have given a major non con for not using the M&S format and we have had auditors who refuse to even look at an allergen risk assessment if it is not in the M&S format.

Has anyone else had any issues with M&S regarding the format of the allergen risk assessment????

[Jean]

We supply all the main UK retailers which include M&S.

Some M&S auditors are happy with our risk assessment as long as the M&S technologist has signed off against the risk assessment.

Other auditors have given a major non con for not using the M&S format and we have had auditors who refuse to even look at an allergen risk assessment if it is not in the M&S format.

Dear Techy4580,



What is M&S ? Kindly excuse my ignornace.

[Techy4580]

Sorry - M&S are Mark's and Spencer who are a UK retailer. They are a high street store that also has a food division selling 'up market' food.

I guess my topic is only really relevant to UK food producers.........

[Charles.C]

Dear techy,

I guess my topic is only really relevant to UK food producers

Not necessarily. I hv experienced this general type of problem for other UK customers who were then supplying M&S but not over allergen related issues.

IMEX, auditor problems over risk assessment hv usually been due to

1. the auditors were simply unable to understand different procedures. The decision was then typically based on request for validation (get out of ignorance card). I am assuming that the difference was not a fundamental PRP vs CCP type disagreement, that can get tricky.

2 Specific data (particularly with respect to validation) items were missing or not in exact agreement between the 2 procedures. This can also be genuinely tricky and depends on the case.

You may hv to give more detail to get a meaningful response. Do you mean for example that you used a 3x3 matrix and they wanted a 5x5 or ??

It makes a change to meet an audit problem not linked to Tesco.

Rgds / Charles.C

PS, BTW, Welcome to the forum !

[Techy4580]

Hi Charles

I think you are absolutely right regarding the fact that some auditors are unable to understand an alternative system. Sadly many of the auditors I come across are blinkered in their approach and if they cannot understand something they will non con it.

The difference between our allergen risk assessment and the M&S risk assesment is in the way in which you actually assess the risk.

In our system we look at the allergenic material and follow it through all our processes and say - ok is there a risk of this allergen cross contaminating a non allergenic material. If so then we must put procedures in place to prevent the allergen from contaminating other material.

In the M&S system they look at the non allergenic material and say is there a risk of mthe material becoming contaminated from an allergenic material. If so then there must be measures in place to protect the non allergenic material.

In effect the M&S system is focusing on protecting the non allergenic material rather than controlling the allergen. So it's ok to splash sesame seeds all over the place as long as you are protecting the non sesame products.

To me that seems a rather silly way to approach the problem. And in addition this approach can be simple to implement if you are a small factory dealing with only one or two allergen but we have factories dealinmg with 12 allergens and it is just impossible to risk assess products in these factories following the M&S system.

The M&S system also only classifies the risk as remote or possible - remote needing no controls, possible requiring controls - so is very black and white,

Our risk assessment considers the relative allergenicity of a material, the physical form and the liklihood - so IMO we consider the risk in far more detail than the M&S system.

How do other sites handle allergen risk assessments?? And have you got any comments from customers/auditing bodies regarding the best way to set out a risk assessment??

Cheers - ST