Hello Skye,
I see no one has replied to you. I think I can understand becauseyou ask a huge question.
I won't pretend to understand your bakery and our factoryassessment may not be appropriate - but I hope I can share our approach toperhaps give you a starter.
The essence is summedup by 'know your enemy' and 'divide and conquer' and you will need to establisha tight objective along the lines 'Limit allergen declarations on labels to ….'or 'Prevent cross contamination from line A to Line B' to help justify thecosts involved.
In advance, I'll apologise if I'm way off-beam or listingthings you are already familiar with - but here's how we approached our 'allergencontamination control and minimisation'
1. List all the allergens you have on site:
· that you use intentionally (I'm guessing: gluten,lactose, egg, sulphites (in sugar and fruit preserves) and perhaps nuts ad afew others)
· that enter your site unintentionally (stafffood, via contractors, transport, neighbours (air borne, etc)
2. Organise the list by finished product (which products containwhich allergen intentionally and which allergen unintentionally) and then againby machine / production line (which machines / lines handle which allergens).This helps put your Risk Assessments into perspective so you can identify thebest route for your analysis, it also helps demonstrate allergen awareness toBRC too.
3. List potential contamination routes and crosscontamination vectors (people, machines, in-house transport (bins, trays etc),conveyors, air borne, shared engineering (CIP pipelines etc). Make sure you challengeyour assumptions, especially if you think some allergens are present only onone machine / line - otherwise simply accept that all your intentional andunintentional allergens are potentially present in all your products.
4. Carefully redefine your cleaning protocols from the pointof view of allergen removal and use test kits backed up by ELIZA tests toverify their efficacy at allergen removal - to provide a means of allergen control.Perhaps identify the machine most likely to be contaminated and the allergenmost difficult to remove to simplify this step (I'm guessing egg and utensilsurfaces - particularly if you use plastic utensils (protein seems to have anaffinity to plastics (oil-based??)) and of course plastic utensils are likelyto be less smooth than metal surfaces). If your cleaning is performedstrategically, you can argue and demonstrate that an allergen may not be presentif / when you don't want it to be.
5. Review ingredient storage and handling to identify and segregateallergens from non-allergens, ensure the allergen tagging follows throughintermediates to finished products waiting to be labelled.
6. Ensure you have allergen-specific utensils, food-protectivewear and staff clean-up when handling allergens and during cleaning operationsto remove allergens. We identify allergen specifics by a colour - purpleingredient bags, product scoops, aprons, gloves, scrubbing brushes, squeegeesetc
7. Turn your lists into Risk Assessments, establish likelihoodand severity. We always viewed allergen contamination (intentional andunintentional) as most severe given anaphylaxis kills - so all of our allergenrisk assessments turn out to be significant. However, I know others considersome allergens to be less severe than others (eg nuts are more severe thangluten) but in my view - severity depends on the affected individual and youwill never know …
8. Product Labelling.
· You are required to declare every intentionalallergen (eg Cake .. Contains egg,lactose, gluten)
· At the moment, declaring potential crosscontaminating (unintentional) allergens is not mandatory and folks usestatements like 'Prepared in premises that also handle sulphites, nuts …'. Inmy view BRC6 suggests that a statement of this kind is required if you can'tdemonstrate sufficient controls are in place to guarantee the absence ofunintentional allergens although the emphasis and site approach must be toreduce the risks of contamination by allergen controls - so be careful not tolean too heavily on this 'catch-all escape'
9. Establish procedures that ensure the situation you justdescribed is achieved and maintained:
· React, review and reassess if your suppliers changethe allergen status of your ingredients
· Record and verify your strategic cleaning to demonstratecontinued allergen control
· Audit your systems
· Establish a test program to demonstrate yourcontrols are actually in control and use an external (UKAS) lab to demonstrateyour tests are valid (ELIZA testing?)
10. Be aware allergen controls are not cheap so seniorcommitment is really a pre-requisite:
· Ingredient labelling and segregation takes time,space and storage / labelling consumables
· Allergen-specific utensils, handling systems,even machines (eg extra blender so your meringues can be whipped up in adifferent blender from your bread mixtures so separating gluten and lactosefrom your egg & sugar (contains sulphites) meringues)
· Additional cleaning take time
· Test kits and ELIZA testing are definitely notcheap (We spent approaching £2k to validate our cleaning on just 1 line andanticipate an annual spend around £5k for routine testing)
There are several useful papers around on the subject of allergencontrols and on Risk Assessments - but I feel the best solution to your requestfor an allergen risk assessment for your bakery - is, I'm afraid to generateone for yourself. In my experience other folks' risk assessments are often veryspecific to their regime and any auditor worth his salt will spot thedifference between their regime and yours very quickly. So I hope this helpsand perhaps stimulates debate in here.
Kind regards and good luck
Graham
