14 replies to this topic

[Brian Furnell]

We manufacture plastic injection moulded containers for the food industry and have the BRC global certificate.
One of our customers wants us to become nut free. To them this means we will have to remove any confectionary sold in our canteen that might have nuts in.
We believe that as we have a no food and no eating policy on the shop floor and a handwash regime before entering the shop floor this is entirely unneccessary. However they seem to be insistant as they believe even a single molecule of the nut protien on our packaging would be a serious risk.

How reasonable is this, if so do we need to ban all food on site, as our staff bring in a lot of their own food, and would we need to have certified nut free food in our canteen?

Any ideas on this would be helpful, especially as to how much nut protien is seen to be dangerous?

[George @ Safefood 360°]

Hi Brian

It's always a difficult one when a customer insists on imposing a rigorous requirement like this. You have to balance the commercial importance of your customer’s business with the impact on your operation and of course the risk to the consumer.

It’s widely accepted that the prevalence and severity of nut allergies in the general population is significant and many food processors take specific precautions to ensure their plants remain free of all possible sources. So it’s not unreasonable and certainly not unusual for customers to make these demands.

It’s not necessary to ban all foods from your premises. Nor is it necessary to certify foods supplied to your canteen. Based on your risk assessment - a practical and well thought out nut policy will do the job. You already have some control measures in place including exclusion and hand washing so you are starting from a good place. The following might help:

1) Draft and introduce a nut free policy for the site.

2) Include the policy in your staff code of practice.

3) Formally make your employees aware of the policy (and the reasons why!) in a short training session.

4) Ideally get your employees to sign-off on the policy.

5) Remove all nut containing products supplied by the canteen and inform purchasing of policy.

6) Clearly post the policy in appropriate staff areas. (List the types of products that contain nuts and are most likely to be brought on site by your employees. Some companies even show photos of these products e.g. chocolate confectionery containing peanuts, cakes etc.)

7) Ensure visitors and external contractors are addressed in your policy.

8) Document your policy and supporting risk assessment.

The risk is probably relatively low – however, it’s important you take your customer’s needs on board. It is always best to do a good risk assessment and work from there; you may find your customer is more open to appropriate levels of control when supported by a good RA.

Best of luck…

G Howlett
 

[Brian Furnell]

Thank you George,

We have tried to do a risk assessment and we believe that the risk is low and our hand washing controls combined with the ban of no eating or any food on the shop floor are suitable safeguards.

I suppose in the end it will be a commercial judgment, I would have like to know the if there is any information on the actual risk level posed.

Regds

Brian

[GMO]

i disagree. It's common accepted practice that to be nut free you should be completely nut free in canteen, packed lunches etc. What if one person didn't wash their hands properly? Can you guarantee that handwashing is 100% effective? Nope, unless you're observing and swabbing everyone, you can't so the risk is there, even if it's small.

Put it another way, how much hassle is it really to go nut free? Staff are not allowed to bring in nuts or products containing nuts and neither is your canteen (note, "may contain nuts" is still allowed normally unless the product actually contains nuts.) It's frankly easy. So then your customer sees that you're being obstructive about a policy which means people would have to have a mars bar rather than a snickers. Sounds petty doesn't it?

I suppose if the customer had a product which then caused a consumer death due to an allergic reaction, are you prepared to defend this in court? Is it really worth it?

[Brian Furnell]

Ok, I am not saying it is not possible,
However what is the actual risk.

If a person handles a nut or nuts and does not wash his hands and then touches a container which is then filled at our customers and that container is then used by someone with a severe nut allergy would there be sufficient nut protien, and how much is sufficient nut protien?, in the food to cause an allergic reaction.

I think at present nobody knows, nobody knows if it is a high risk or no risk at all.

Putting procedures in place is easy. Monitoring and auditing them needs to be carried out and also training and retraining - disciplinary hearings, etc etc all add to the complexity and cost of what we do.

Therefore I ask what is the risk?

[GMO]

I introduced a nut free policy at a site which had previously allowed nuts. There was a brief, signage etc done. No nuts were found on audits. One incident occurred where a pack of crunchy nut cornflakes was found in a kitchen by chance (but these were well out of date and so presumably had been brought in prior to the ban and were disposed of.) Additional man hours required? Probably 10 hours total as a generous estimate and then it was added onto audits which were already being done so no ongoing cost.

Yes the risk is small but I suggest you think about that lovely legal phrase "reasonably practicable". Is it reasonably practicable to ban nuts? Yes. It's cheap and effective; far more so I would argue than just relying on people washing hands.

And yes, no-one knows what the risks are if they're honest. But it's a simple thought process for me of consequences, probability and cost. The consequences could be death. The probability is low (but not impossible) and the cost is low. Therefore, for me, I would ban the nuts because of the consequences and cost, despite the likelihood being low.

I often cite this but in the Cadbury's Salmonellae case, they thought that as no case had been proven with <10 cfug-1 of Salmonellae, <10cfug-1 did not cause disease. They were wrong and fined a lot of money as a result. I'm just thinking through due diligence; if you could take a step that's cheap and reasonable to prevent an issue (even if it's already low risk), why the devil wouldn't you? It strikes me it's more about proving a point than really assessing the risk. In life we all have to accept things being a bit imposed on us even when we believe the risks to be minimal. The risks are minimal that someone could cause an illness by handling cases of product (rather than open product) but I still tell people to wash their hands before going into packed product areas.

I once got told by a machine manufacturer that a particular part of a machine "never broke". 5 breakages later in the space of a month they were still telling me this part would "never break". "Never" is not a word in food safety IMO, it's just controlling different levels of risk and by banning nuts altogether you reduce the risks a little bit more.

[Charles.C]

Dear Brian Furnell,

Conceptually I favour GMO's logic although i (cheerfully) admit to being instinctively risk adverse.

The absolute risk obviously depends on yr process / environment although IMO human nature is unlikely to minimise the risk where alternatives exist (Sod's Law*). The (high) frequency of allergen labelling recalls illustrates the official viewpoint on the overall subject (the potential seriousness cannot be denied).

Surely this topic must hv been already minutely pored over by people like FSA ?. I predict that a recommended (minimum) menu of requirements (vis-a-vis due diligence) exists (somewhere).

* http://www.heretical...x/sodslaws.html

Rgds / Charles.C

[George @ Safefood 360°]

Hi Brian

It is unlikely you'll find the data you require to assess the actual risk posed by food packaging manufacturers supplying food packaging. Risk assessments are more often characterised by what we DONT know rather than what we do. The gaps in our knowledge are usually filled by precautionary actions (and reactions) particularly in the legal framework.

No plant or operation (no matter how well controlled) can eliminate risk. Even food products declared 'Free From' are only 'free' to the sensitivity of the testing method used to certify them. Currently in Ireland 40% of product recalls from the market are for undeclared allergens and this reflects the legislative requirement and regulatory response. Safe food and Legal food is not always the same thing and food retailers and processors have no choice but to ensure as far as they can that the risk is reduced to an acceptable level.

I think your assessment probably reflects the actual risk and your frustration is understandable. So until more data on the actual risk comes to light you might be well advised to put in place a nut free policy. You may be surprised by how little it disrupts your operation once everyone gets use to it.

G Howlett.

[Kamwenji Njuma]

Dear Brian,

I think the BRC auditors are becoming more sentitive with Allegens thus you have no choice but adapt the no nuts policy.I think the staff carrying foods should be advised to carry milk,fish and nut free foods and also i would suggest you should site your canteen away from the production area where hand washing facilities are provided to make complete segregation from production operations.

Regards,
Kamwenji

[BBrandDesign]

Nut allergy is an increasingly recognised problem. Asthma is known to increase the risk of death in people with nut allergy. A good rule for people with serious food allergy is: "IF YOU DO NOT KNOW WHAT IT CONTAINS, IT MUST NOT PASS YOUR LIPS. But it’s not possible to ban all foods that contain nuts. Hand washing is so important. George Howlett I really appreciate your premises you given here.

[BBrandDesign]

I also believe that it should be good to have a nut free packaging as nut packaging involves big risk to handle as well as for transportation purpose.

[ctzinck]

forgive me for breathing new life into an old discussion, but are there any 3rd party nut free certification bodies? I have searched google and cant find any. how does one become nut free certified? as a food packaging supplier we have a customer who has said they may require us to be nut free certified.

[Simon]

Forgive me for breathing new life into an old discussion, but are there any 3rd party nut free certification bodies? I have searched google and cant find any. how does one become nut free certified? as a food packaging supplier we have a customer who has said they may require us to be nut free certified.

 

It's a new one to me, I've never heard of it, but then again I'm willing to learn.

[ctzinck]

from what little i can find there is no such thing as a 3rd party nut free certification, no one will come audit you and give you a certificate, the companies that are saying they are certified nut free are certifying themselves.

[Simon]

from what little i can find there is no such thing as a 3rd party nut free certification, no one will come audit you and give you a certificate, the companies that are saying they are certified nut free are certifying themselves.

 

That would be my thinking as well ctzink.