7 replies to this topic

[jaredkkrischel]

We have a research and development lab in our factory. The R&D lab does deal with allergens but does not have a strict allergen control program. The products they develop don't necessarily come into the plant because the lab is segregated from the production areas. Is it a BRC requirement for them to develop an allergen control program for the sample products they make in the lab for customers? When they send concepts to customers they do not put allergen declarations on the product. I know i should do a risk assessment on this, but from what the people in R&D are telling me is that they have never heard of any other R&D labs that have allergen control procedures for the lab itself.

Thanks in advance!!
jared

[Martinblue]

It is similar to having NPD section in a food production area. Handing of all the allergen in R&D should be risk assessed and sample products-sent
to customer should be labelled with allergen information- you never know is tasting on the other end...
regards
martinblue

[SQFconsultant]

Me thinks the folks in R&D are pulling your leg or it might be they don't interact that much with other R&D people. I see in my travels that the majority have allergen programs in place.

[shea quay]

Ha ha! Good old R&D!
From your perspective (I'm guessing you are in Quality) it is vital that R&D have controls in place. I've had experiences where a product has been developed and approved and dumped on my desk only for me to have to meekly return and say "erm, we can't actually do this nut topped nut product as we are a nut free site at the request of one of our major customers". Lousy quality, spoiling everyone's fun!
The risk assessment doesn't have to be complicated. For every trial ingredient we bring on site, we use a one page sheet asking simple questions - any physical hazards, chemical hazards, microbiological hazards, intrinsic hazards (food dyes, allergens and so on...). I like to think it shows that I am aware of the trial raw ingredients we store (not always the case though..). I am open to correction here, but I wouldn't necessarily see the need for a full allergen control programme within the lab itself however. Given your circumstances you could get away with labelling all finished samples with allergen information and a "may contain" statement on all other allergens and having a stricter second approval before ingredients/raw materials are brought into production. This would save you unnecessary complicated cleandowns that may require verification of cleaning processes within the lab itself. However, some auditors may pick up on the risk of cross contamination from staff clothes / footware between production and lab. Most R&D professionals avoid this scenario by constructing their lairs in dormant volcanoes, I find.

[jaredkkrischel]

Shea Quay,

Would you be able to provide me with a sample of the risk assessment that you are using. I think it is a great idea to meet all food safety requirements while keeping it short and to the point with the R&D personnel. If you could let you use a sample I would really appreciate it!!!

Thanks,
Jared

[Charles.C]

Shea Quay,

Would you be able to provide me with a sample of the risk assessment that you are using. I think it is a great idea to meet all food safety requirements while keeping it short and to the point with the R&D personnel. If you could let you use a sample I would really appreciate it!!!

Thanks,
Jared

Dear jaredkkrischel,

provide me with

I presume you meant "post".

Rgds / Charles.C

[Ian R]

Hi
My experience with BRC audits and NPD is that whenever the operation is located in the factory it has been treated as part of the factory.
Hence they need to have some form of allergen control and a risk assessment that justifies that control.

If R&D don't want to be subject to the same controls as the factory the best option is to put them in a shed at the bottom of the garden.

[shea quay]

Hey Jared,
as I say, this is what I've used in the past. I'm sure there are other out there who would go into much greater detail. This system has caught me out on occasion during audits due to my own stupidness/lazyness. It can be very easy to fill out "no risk" as an answer without bothering to do the research!
The layout is a simple, tabulated, single page document detailing the following:

Name of product

Supplier of Ingredient

Production or Kitchen sample (it is importnat to remember that your supplier may themselves be trialling this ingredient and making up samples in a similar R&D kitchen with poor allergen controls)


Ingredients (where applicable, include processing aids)

Allergens Present

Storage Requirements

Microbial Hazards

Microbial Controls (e.g. cooking, frozen product etc)


Chemical Hazards

Chemical Controls

Physical Hazards

Physical Controls

Intrinsic Hazards

Intrinsic Controls (e.g. correct mixing times for dilution of preservatives etc)




This will give you some control of the ingredients that are brought into the lab. If ingredients are then transferred to the factory floor, the following four questions are asked;

Does This Product Raise and Hazard Not Currently Covered By the Hazard Analysis?

Is it Necessary to Carry Out a Full HACCP Review?

Will new ingredient require a new chemical analysis to be carried out on the final product?

Is New Ingredient Approved for Production?

The procedure we use with this calls for full specifications to be sent in prior to delivery (never happens if I'm honest, but you can try). All samples must be sent for the attention of the Quality Manager (not the R&D) and are not released to R&D until approved. It is always worth ringing technical at the suppliers as they are normally quite helpful. Hope this helps.