3 replies to this topic

[verona]

hi i work in a vegetable packhouse an i have recently taken over from the food safety person. in her previous audit a non comformance was raisded stating she did not consider "sodium metabisulphite" also known as chipwhite as an allergen in her program. im unsure how to rectify this as we use it in most of our products.

i have attached her management policy, im sure this is not good enough

Allergen ManagementProgram

We at AfricanBeginnings are committed to being a reliable supplier of safe, wholesome foodthat is appealing and appetizing to our Customers and their Customers.



The followingprocess is in place to prevent allergen contamination on non-allergen raw material:



· All allergen raw materials arestored and processed separate from all non-allergen raw materials.

· All equipment use for allergenraw material is kept separate, cleaned and sanitized away from all othernon-allergen equipment.

· All allergen waste material isdisposed of immediately in the waste area to prevent non-allergen productioncontamination.

· The whole Pack Shed getscleaned and sanitized on a daily basis before work commences and afterproduction ends for the day. And it is also Deep Cleansed once a week.

[Charles.C]

hi i work in a vegetable packhouse an i have recently taken over from the food safety person. in her previous audit a non comformance was raisded stating she did not consider "sodium metabisulphite" also known as chipwhite as an allergen in her program. im unsure how to rectify this as we use it in most of our products.
i have attached her management policy, im sure this is not good enough

Allergen Management Program

We at African Beginnings are committed to being a reliable supplier of safe, wholesome food that is appealing and appetizing to our Customers and their Customers.

The following process is in place to prevent allergen contamination on non-allergen raw material:

· All allergen raw materials are stored and processed separate from all non-allergen raw materials.
· All equipment use for allergen raw material is kept separate, cleaned and sanitized away from all other non-allergen equipment.
· All allergen waste material isdisposed of immediately in the waste area to prevent non-allergen productioncontamination.
· The whole Pack Shed gets cleaned and sanitized on a daily basis before work commences and after production ends for the day. And it is also Deep Cleansed once a week.

Dear verona,

hi i work in a vegetable packhouse an i have recently taken over from the food safety person. in her previous audit a non comformance was raisded stating she did not consider "sodium metabisulphite" also known as chipwhite as an allergen in her program. im unsure how to rectify this as we use it in most of our products.

For the benefit of other readers, note that above query / discussion is duplicated here -
http://www.ifsqn.com...dpost__p__58949

So I presume this thread is only asking for comments on the policy as per the thread's heading.

Rgds / Charles.C

[williamw]

This seems to be more of a generic policy statement than an actual program. Depending upon how your system is structured there may be other other documents such as procedures and work instructions that relate to this so those would be important to include in evaluating your allergen management program. This is more of a policy statement that says what you do but not how you do it.

For example:

How are allergenic materials identified so that those handling the material know what is and is not an allergen?
How exactly are allergens stored "separately?" If you have an allergen storage area but store more than one type of allergen in the same area how are the various types of allergens separated so as not to have cross contact with each other?

How are allergens "processed separately?" Dedicated equipment? Sanitation between runs? Production sequencing?

Have you validated you cleaning methods to show that they indeed remove the allergens?

These are just some of the things you need to think about in developing a full scale allergen control program.

Regarding the specific sulfite ingredient the requirements will likely vary by locale. In the US sulfites must be declared on the label if they are present at 10 ppm or higher. In this case you would need a program that assures that sulfites are labeled on all products that intentionally contain them and assure that your product change over and cleaning procedures will prevent cross contact with non sulfite containing products that would result in 10 ppm or more in the product.

Don't confuse sulfites with other allergens either -- sulfites are technically not an allergen but a sensitizing agent, although that distinction is not really important for a control program. However -- at least in the US -- sulfites have an established lower limit while at present there is no comparable lower limit for the true food allergens, so depending upon you situation those may be more difficult to control.

Hope this helps a bit, there is a lot more to be said on the subject but maybe this will get you thinking in the right direction.

[Charles.C]

Dear verona,

As noted / explained in previous post, yr post suggests some terminology confusion. It’s not unusual on this forum.

“Program” is a word of undefined scope IMO. Precise interpretation may also depend on yr local regulations (if any) or any other relevant standard.

The ISO Quality triangle flexibly suggests the (typically expanding) series Policy > Procedure > Work Function.
(sometimes “procedure” includes the work instruction”)

As example only -

Policy: a set of principles that is used as a guide for action, esp. in a government or business.
Procedures: a series of actions necessary for accomplishing a particular goal; course of action

(of course “principle” is undefined but at least we mostly have some idea what this means)

I suggest “Program” is between policy and procedure but it could equally include Work Instructions depending on yr own preferences. It could also include the Policy, or be a book.

If interested in semantics can see this thread -

http://www.ifsqn.com...dpost__p__48675

Here is one example of a (stated) Allergen Policy-
http://www.dovesfarm...lergens-policy/

IMO, yr current “program” is a set of very brief “procedures”. Others here may well disagree. It certainly does not constitute a "program" in my understanding of the term which could likely include items such as elaborated in previous post. It is convenient IMO to follow a structured route tailored to your own production. There are numerous illustrative examples / attachments on this forum such as –

http://www.ifsqn.com...dpost__p__51372

http://www.ifsqn.com...dpost__p__58320

or  bb1 - afgc allergen guide.pdf   594.52KB   351 downloads

Maybe try a little searching for “allergen” to see the options.

Rgds / Charles.C