13 replies to this topic

[John Antecki]

My question is in a plant that makes multiple products containing any one of the "Big 8" allergens the FDA has dictated, how should one go about creating an Allergen Control Program?
We have a;
-Validated Sanitation Program
-Changeover procedure
-Dedicated lined
-Proper Scheduling
All the raw materials we use are dictated by each individual costumer, who we buy from, what we buy, how much we buy and when to do so, all are decided by a costumer.
Of course they all follow the Food Allergen Labeling and Consumer Protection Act of 2004 which makes companies must state in one of four ways (Contains, may contain, this product was produced in equipment, so on and so forth)
so each product is labeled, but not well enough
I've already decided to color code these allergens but outside of identification, storage (vertical), how can i ensure and demonstrate control in process,
Should a risk assessment out side of the haccp hazard analysis, be done for each product? sort of a Allergen CCP? and if so any one know of any forms i could use?
what else can be done?

Does any one see missing Controls?

Thanks for all your help in advance!!

Edited by John Antecki, 17 November 2010 - 02:49 PM.

[Foodworker]

It is difficult if your operation can potentially handle any of the recognised allergens.

A full allergen risk assessmenent of all raw materials is an absolute necessity as a starting point. Of the allergens that you identify from this, some are recognised as being of greater risk to consumers - peanuts, tree nuts, milk and fish particularly.

If you handle peanuts for example, you may want to consider processing these in dedicated rooms with barrier hygiene controls. This is becoming more common in the UK.

You mention that you have a validated sanitation programme, but you could also look at positive release of equipment after cleaning using allergen swabs.

A couple of areas that you don't list are spillage and corrective actions procedures and training and personnel practices with respect to allergens.

There are many information sources on the net and there are some good threads elsewhere in these forums

This is a checkist that I sometimes use.

Attached Files

•  Allergen Checklist.doc   65.5KB   613 downloads

[John Antecki]

It is difficult if your operation can potentially handle any of the recognised allergens.

A full allergen risk assessmenent of all raw materials is an absolute necessity as a starting point. Of the allergens that you identify from this, some are recognised as being of greater risk to consumers - peanuts, tree nuts, milk and fish particularly.

If you handle peanuts for example, you may want to consider processing these in dedicated rooms with barrier hygiene controls. This is becoming more common in the UK.

You mention that you have a validated sanitation programme, but you could also look at positive release of equipment after cleaning using allergen swabs.

A couple of areas that you don't list are spillage and corrective actions procedures and training and personnel practices with respect to allergens.

There are many information sources on the net and there are some good threads elsewhere in these forums

This is a checkist that I sometimes use.

Spillage and corrective actions procedure is basically where we fail, you know they just clean up, its really dependent on Training, Accountability, and Direction from Senior management. I get "Whats wrong with the way we've always done it?" alot, People take change the wrong way, sometimes, its not that they are doing anything wrong their just not doing it right.
Thanks alot for the DOC!

Edited by John Antecki, 18 November 2010 - 12:55 PM.

[Charles.C]

Dear Foodworker,

Nice Checklist

Rgds / Charles.C

[Tony-C]

Does any one see missing Controls?

Thanks for all your help in advance!!

I don't see packaging controls in there. We used to have segregated locked areas, different coloured liners/bags for allergens and a system of booking in and out and balance of stock after packing.

Regards,

Tony

[Confussed]

hi, i am also implementing an allergen program. We are a manufacture value-added products. All of our products are flash fried through a fryer. Can allergens be transferred from one product to another through the oil???

regards


Sheetal

[Tony-C]

hi, i am also implementing an allergen program. We are a manufacture value-added products. All of our products are flash fried through a fryer. Can allergens be transferred from one product to another through the oil???

regards

Sheetal

Yes you will need to consider using a separate oil/fryer

Regards,

Tony

[cosmo]

Should a risk assessment out side of the haccp hazard analysis, be done for each product? sort of a Allergen CCP? and if so any one know of any forms i could use?

Hi John
I use, and also have my suppliers fill in, these forms to do the allergen risk analysis.
The Vital form is about calculating and measuring any allergenic product remaining in the process, and based on the level of protein cross contamination it also indicates the labelling requirement (does contain, may contain etc) http://www.allergenb...gistration-form
The second form is for product information (for product and ingredients) and their known potential cross contaminants.
This helps with assessing the allergen risk. http://www.allergenb....3-17-12-10.xls
One thing to be mindful of is that different countries have different standards, so check the level of contaminant that determines which precautionary ststement is used.
I trust you will find these tools useful.
Cosmo

[jaredkkrischel]

When you say you color coded the allergens, do you mean you color coded the utensils used for allergens?
If so, do you have a color for each allergen or just a color for allergens in general.

I am wondering because I am in the same process.

Thanks,
jaredkkrischel

Edited by jaredkkrischel, 30 March 2011 - 08:19 PM.

[cosmo]

When you say you color coded the allergens, do you mean you color coded the utensils used for allergens?
If so, do you have a color for each allergen or just a color for allergens in general.

I am wondering because I am in the same process.

Thanks,
jaredkkrischel

Hi jaeredkkrischel,
I believe what John was talking about was colour coding each allergen as he mentions products with one or multiple combinations of the big 8 allergens.
It would make sence to identify each allergen to prevent cross contamination especially as they are/should be declared on the label if present.
Each allergen should also have dedicated utensils, unless a good monitored hygiene program is in place, to again minimise cross contamination potential. Also don't forget to swab utensils and common work surfaces when validating your cleaning schedules, considering 30% of allergen experiences originate from unlabelled/undeclared allergens.
cosmo

[John Antecki]

Hi jaeredkkrischel,
I believe what John was talking about was colour coding each allergen as he mentions products with one or multiple combinations of the big 8 allergens.
It would make sence to identify each allergen to prevent cross contamination especially as they are/should be declared on the label if present.
Each allergen should also have dedicated utensils, unless a good monitored hygiene program is in place, to again minimise cross contamination potential. Also don't forget to swab utensils and common work surfaces when validating your cleaning schedules, considering 30% of allergen experiences originate from unlabelled/undeclared allergens.
cosmo

Thanks for every ones help in this matter!

As for some of the insight passed down here goes... we had dedicated production lines for allergen production so it made alot of sense financially and efficiently to attach the allergen production tools, which are only a few, to the equipment where they were need and like usual applied the allergen clean and san to the machine including the allergen utensils as well as the swabbing and 3D method for validation.

We handle, regularly around 30 raw materials that contain allergen so the color coding raw materials to identify allergens and maintain vertical storage this is going well after a ton of training, our documentation audit went very well and the only problem the found for 6.13 was warehouse need to also state a cleanup procedure.
The VITAL docs would work out great but we only produce semi-finished goods so labeling controls are out of our realm. but great system if some one has a need to do allergen label declarations.

Thanks again to everyone.

[n_quality]

i am currently putting together a changeover procedure and cleaning. we interchange between pdts containing milk and non milk products. Could someone please help with changeover procedures. any help would be appreciated

[Charles.C]

i am currently putting together a changeover procedure and cleaning. we interchange between pdts containing milk and non milk products. Could someone please help with changeover procedures. any help would be appreciated

pdts

= ?????

Rgds / Charles.C

[n_quality]

Cereals please. do i need a risk assessment. youre help would be much appreciated. Thanks

= ?????

Rgds / Charles.C