Going "Nut Free" (sesame too...)

We have always had a nut-free manufacturing area and I was trying to put in place policies and controls to manage nuts brought into the canteen etc when evenutally it was decided to go nut and sesame-free as a company i.e. prohibit employees and visitors from bringing in any foods containing nuts/peanuts/sesame.
I need a policy that everyone will sign to ensure understanding and the importance of compliance. There are many questions about what sort of foods are no longer allowed and I would like to include this as a prompt list. There is a basic one in the FSA info I have, but does anyone have something more detailed I could use please?
Also a specific question: Does coconut need to be included? Is it really a 'nut'? It is not listed as such in my FSA publication but I don't know for sure if it comes under allergen control?

Hello


This is a list of products which a client of us send me.
Maybe it can be some help, as coconut is not one of these products.


Good luck!


Anne

We have a total ban on nuts arcoss the site including people who work in the offices and would never go to the factory floor. Nobody is allowed to bring any nuts or nut containing products even as a snack in the canteen (which does not stock nut products).

It is easy for employees to understand the likes of peanuts, cashewnuts etc but you also have to stress the importance of not bringing in things like Snickers, M&Ms and something a lot of people wouldn't think about, hazelnut yoghurt.

We treat an incident of bringing in nuts as a clear breach of hygiene rules and repeated incidents would be treated as gross-misconduct and would lead to the employee's dismissal (never happened, fortunately); the problem with going down this road if you never had a nut-free policy before is that you will need to get both employees and the Union on side; to do this you need to explain your customer requirements and it is essential to keep their business and ultimately safeguard jobs

Coconut is not classed as an allergen unless it contain sulphites which is minor in comparison to nuts; doesn't need to be banned under the nut-free policy

Thanks both.
Anne Z - good idea and I will ask our Regulatory Dept who deal with questionnaires if they have any other detailed lists too.
redchariot - in the draft policy I have already spelled out clearly that contravention may lead to disciplinary action (and this should not be new for production anyway).

Don't forget hummous contains sesame and the ones people always forget is tins of Roses and Quality Street at Christmas! But then I can't talk; I once brought in some Baklava into a site forgetting what I was doing! Tsk, tsk, naughty GMO!

Hello all,

I am sorry!
I do not know any nut free companies, as you described.

Is there really a risk if a worker eats peanuts in the canteen, breath above the products and in this way contaminate the product with allergen spores.

Hello all,

I am sorry!
I do not know any nut free companies, as you described.

Is there really a risk if a worker eats peanuts in the canteen, breath above the products and in this way contaminate the product with allergen spores.

It's perceived to be. I suppose the argument is that as handwashing is generally a PRP you can't be 100% sure it's completely effective and yes, if traces were on the hands it can be enough for some particularly allergenic individuals.

I believe nut allergy is far more common in the UK; it's the most common food allergy by a long way. It kills people, not a lot but frankly if that was my mother, husband, sister or son I'd be keen they weren't!

There was some recent research published by the FSA on people's attitudes if they have a food allergy and it found that 'may contain' statements were largely ignored.

As part of HACCP you have to think about your consumer including vulnerable groups and how the product could be misused, e.g. by a nut allergy sufferer ignoring the 'may contain' statement.

I think as it's almost impossible to say "this amount of contamination is dangerous" for allergenic individuals because it varies from person to person, it makes sense for the most common food allergy to ban it completely where it's not an ingredient. This is because it's easy to do. How much hassle is it really to say to people "have a Mars bar not a Snickers"?

I believe nut allergy is far more common in the UK; it's the most common food allergy by a long way. It kills people, not a lot but frankly if that was my mother, husband, sister or son I'd be keen they weren't!

Allergies are indeed more common in UK, but the Netherlands are not far behind.
I recently joined a presentation from an allergy consultant. She was allergic herself. I always find these presentation quite shocking. for me, there were 2 new things in this presentation:
1) traces to be effected are always given in ppm. I do not have any picture for ppm. She told us that it was a spoon on a big bag. That is quite a picture that I can use and explain to others.
2) it is not true that peanut and nut allergy are worser then others. Depending on the person and the products, persons can also die from other allergens. It is also not true that the amount of traces for effect is smaller for peanuts.

There was some recent research published by the FSA on people's attitudes if they have a food allergy and it found that 'may contain' statements were largely ignored.

Of course they do! Whaty should they do else?
Since it is legal to declare the 14 allergens and to make sure that cross contamination is excluded from your production facility, producers started to declare allergens as 'may contain'. Just to prevent receiving claims and to get rid of their responsibility.
For persons suffering from allergy, these 'may contain' claims are the worst. In earlier days they eat this product and did not had any problems with it or they know from experience they better not eat the product. Nowadays, a lot of companies claim 'may contain'. And 'may contain' includes allergens on site, but not in the product, but also includes allergen indicated as 'may contain' in one of the ingredients. So, it is unclear what kind of information 'may contain' is, and the persons suffering from an allergy are not helped with this claim. This claim is only for companies.
I have seen companies taking no responsibilities at all and just claiming alle allergens as 'may contain'. These companies exclude allergenic people to be customer of their products. Thinking in a commercial way: excluding 3% of the population might be cheaper then the costs of a recall and the lost of confidence after a recall..
So the allergy persons are back to the beginning and have to make a risk assessment themselves for each product they are buying and eating. Just like they use to do before.
Globalising food processing also confuses these persons. I have seen examples of a global chocolate brand with several processing locations. A specific product was produced in two different plants in different countries in Europe. The name and label of the product was the same, except for the may contain claim, because in the first factory nuts and peanuts were handled and the second factory was nut free. Mostly allergenic people remember the brands and products that hey can eat. On the packaging no reference is made to the processing plant.

it makes sense for the most common food allergy to ban it completely where it's not an ingredient. This is because it's easy to do. How much hassle is it really to say to people "have a Mars bar not a Snickers"?

I think it is just very hard to do and how far should you go?
If you, GMO, as an expert, did not knew that Baklava contains nuts, how would you expect that some one, who has no mother, sister, brother, father, uncle, etc. with allergen experience, will know this and will understand the risks?
For peanut butter, peanuts, snickers, nuts, etc. it is clear not to eat it, but how about other products? How about Nutella? How about the candy bar that is produced in the line next to the snickers? How about products still to be developed? There are people who do not know that sesame crackers are made from sesame or tacos from mais.
It will work if you have only own workers and train them very well. But how about these temporary workers from agencies? How about the young worker, whose lunch is made by his mother?

On the other hand --> nut free is certainly much much much better then 'may contain'.

It just seems so awful hard to implement and maintain.

Vey good and detailed analysis,
Thanks Madam

Martinblue

I should have blooming known that baklava contained nuts but I was struggling; had been through loads of stress at work and was only getting 2 hours sleep at night, so not really a defence but we're all fallible.

Unfortunately however accurate the analysis, the 'nut free' site has become the norm. As ever, I'm sure you can risk assess and validate by doing allergen swabs but it's a lot of effort. I think when it comes to things like this, it's a good idea to think about UK health and safety legislation. They have a clause saying you need to do what is 'reasonably practicable' and that means balancing the risk with cost and ease of implementation. I suppose the thing is if you did have an issue (or more likely someone accused you of having one) would a court think you'd done everything you could if say you have a nut free product, you state it's nut free but allow nuts on site?

I don't know, it is an issue which causes some whinging but it's really not that hard to implement. If it takes the risk down by only a small amount, I'd still do it.

Thanks for the discussion.
I have hummous on my list and have already given the Snickers/Mars bar comparison at briefings as a good example of how to substitute things. The tins of choccies at Christmas has also already been pointed out and will surely be the biggest argument but never mind, there's always biscuits and fudge etc. The risk to our products was already almost nil but I keep in mind something that Simon said somewhere else on here: the aim is basically to move the auditor onto the next question. Even if nuts are almost of no consequence to our products, is it easy to go nut-free? Yes. And that avoids any detailed digging by an auditor on how we protect the products from the canteen and employee lunch boxes.

It's important to point out to the staff that it's only things obviously containing nuts in the ingredients which need to be excluded. Some manufacturers put 'may contain' statements on which isn't all that helpful and if you restricted them too your staff would have very little to eat.

For chocolate selections, I think Cadbury's Heroes don't contain nuts, Nestle 50 minis don't either and haribo multipacks are nut free. I know they're all a bit 'kiddy' but most adults secretly like kids sweets...

Small questions:

- How far do you want to go in banning different products? It seems to me you al ready have a long list.
- And how do you control it? Are you checking all the lunchboxes all the time?

As I assume it is prohibited to eat and drink in the production area + they need to wash their hands etc. What are the changes to find the different nut traces in the finished product? I don't know how much peanut traces you transfer if you eat a snicker in the canteen, wash your hands and then start work.

Like GMO said 'reasonably practicable'. Here only peanuts are banned.

Thanks again. I think I'm on the right track as I also already explained that the "May contain nuts", "Produced in a factory that processes nuts" etc are okay or as GMO says it may be a diet of bread and water (and the bread may need scrutiny...!).
Unfortunately according to the Cadbury website, at them moment Heroes contains Dairy Milk Wholenut (one of my favourites by the way.... boo-hoo...).