Allergen Plan

Dear All,

I need some help regarding this matter, My company is one of leading home-made cookies in my country and  a customer request that my company should come out with an allergen plan since we do not have any GSFI scheme certificate. Currently we only possessed  ISO 22k & HACCP cert and my dilemma is why should we come out for allergen plan since we never intended to produce allergen free or gluten free product. I have briefly go through some articles regarding allergen control plan and think that the only solution that we can pull is to have the have allergen declaration label on the packaging(we already did that since it is required by the ISO 22K) futhermore we did classified allergen as potential hazards in hazard analysis(under chemical hazard). So any idea how should I come out with an allergen plan since all the products contains some of 8 major allergen as basic ingredients.

Hi, NurAnnie;

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:
 

2.8.2.1 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

safety plan.

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

possible.

Dear NurAnnie,

Specifically, the control aspect may relate as to whether your (apparently produced) range of cookies have identical allergenic hazards ? If otherwise, the labelling is presumably different and then any possible production schedule / cross-contamination hazard needs to be justified accordingly, ie by a plan. Such plans have been previously discussed on this forum. For example can see this thread -

http://www.ifsqn.com...rix/#entry61883

Rgds / Charles.C

PS - strictly speaking, there is no such thing as a GFSI scheme certificate.

now i get the picture. thank you charles & slab

While you don't make any specific claims regarding allergens on the labels the policy of many retailers is that blanket declarations of all possible allergens is not acceptable and the company needs to put a plan in place to reduce the risk of cross-contamination of allergens. This is due to legal requirements and indeed the marketing impact of having a long list of allergens on the label.

The above advise is excellent for putting such a plan in place.

George