Most likely what the company is looking for at a minimum is an annual validation/reassessment of both manufacturing processes (total throughput to include raw material COA, SSOP, and HACCP) and label policy validation (but it would be best to ask your customer for formal requirements).
I have the following in place outlined, but omitted the verbiage:
- Allergen Policy
- Allergen Policy annual review letter (signed by Food Safety committee members)
- Label Policy
- Label Policy annual review letter (ditto)
- Label Verification Records (frequency varies on regulation)
Here is the latest SQF code on the topic:
22.214.171.124 The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented. The allergen management program shall include
i. A risk analysis of those raw materials, ingredients and processing aids, including
food grade lubricants, that contain allergens;
ii. A register of allergens which is applicable in the country of manufacture and the country(ies) of destination;
iii. A list of allergens which is accessible by relevant staff.
iv. The hazards associated with allergens and their control incorporated into the food
v. Instructions on how to identify, handle, store and segregate raw materials containing allergens provided to staff
responsible for receiving those target raw materials.
vi. Provision to clearly identify and segregate foods that contain allergens,
vii. Cleaning and sanitation of product contact surfaces between line changeovers shall be effective, appropriate to the risk and
legal requirements, and sufficient to remove all potential target allergens from product contact surfaces, including
aerosols as appropriate, to prevent cross contact.
viii. Based on risk assessment, procedures for validation and verification of the effectiveness of the cleaning and
sanitation of areas and equipment in which allergens are used shall be effectively implemented.
ix. Separate handling and production equipment where satisfactory line hygiene and clean-up or segregation is not