Validation for nut ingredients separated at receiving

The scope of this HACCP plan is for no nut cookies from receiving of materials to shipping finished product. cookies containing tree nut and peanut are also made in the facility.

We require our ingredient suppliers to separate peanut and tree nut ingredients from other materials using either a slip sheet or a separate pallet. it's monitored via visual inspection and we have never experienced a customer complaint relating to an allergic reaction to a nut ingredient not listed in any product's ingredients.

The Questions: Can I validate the control of this hazard by stating company experience? Other ideas on how to monitor or restate the control?

Thanks,

-Zach

BUMP

BUMP

I'll fill in until someone more knowledgeable comes along -(always the bridesmaid never the bride!)

It has always been my understanding that 'structural separation' was the ideal-considering the minute quantities of peanut protein required to cause an issue (anecdotally a loael of 0.25mg) -so not sure the separate pallet/slip sheet thing goes far enough?(i am sure someone will correct me on this)-though i guess if the nut and non nut products are sharing 'production space' even if running dedicated lines- there might be more significant areas of concern-so maybe i am being pedantic!

Anyway until someone more nutty(!) comes along, attached is my favourite bit of bedtime reading -the GMA Nut Handbook!

Regards

Mike

Dear Zachfizz,

It seems to me that what you are presently referring to is verification, not validation.
I appreciate that the terminology may be geographically sensitive but i am not quite sure what you actually want. validation is supposedly implemented prior to the routine process usage and typically involves a validatably ( ) analogous reference or a designed challenge test to demonstrate achievability of a specified target or something similar. The use of subsequent process data is supposed to "verify" the original "validation". Some industries have variously staged "validations" also but I doubt that idea applies here.

So, what was yr original operational target ?? I guess it will depend on yr actual process layout also ? There is a considerable stock of allergenic protection posts on this forum if you look around a bit. I think yr problem has occurred before.

Rgds / Charles.C

You could validate your process by conducting allergen testing on the incoming ingredients. A good way would be to swab and test the slip sheets, pallets or packaging used for any type of peanut residue. I know you can test for peanut specifically, not sure about any of the tree nuts.

If you conduct tests and find peanut residue on tree nut slip sheets, pallets or packaging then you may still have a risk.

Similar monitoring could be done once you show that you can get things residue free.