23 replies to this topic

[KTD]

Had an auditor come through recently who said that we have allergens misclassified as Chemical Hazards. In the US, USDA has traditionally only recognized physical, chemical, and biological hazards. I know that there were some struggles in the US with classifying prions (Mad Cow disease) under biological, as they are not a living organism. Is any recognized group in the process of defining other potential hazard classifications? Where are you classifying allergens?

[chrisbird616]

We have always classified allergens as chemical - what else could they be?!?

 

(from a FDA certified company)

[cazyncymru]

MMM I classify allergens as allergens!

 

In my HACCP, I have Chemical, Microbiological , Physical & Allergen (clause 2.7.1  of BRC V6 & Clause 5.2 of BRC V6)

 

Not sure about other standards

 

Caz x

[debaduttajayaprakash]

They are not chemical hazards in a strict sense but nothing wrong to include it as chemical hazard . 

[Charles.C]

Had an auditor come through recently who said that we have allergens misclassified as Chemical Hazards. In the US, USDA has traditionally only recognized physical, chemical, and biological hazards. I know that there were some struggles in the US with classifying prions (Mad Cow disease) under biological, as they are not a living organism. Is any recognized group in the process of defining other potential hazard classifications? Where are you classifying allergens?

Dear KTD,

 

A food allergy is an adverse immune response to a food protein.They are distinct from other adverse responses to food, such as food intolerance, pharmacological reactions, and toxin-mediated reactions.

http://en.wikipedia....rgy#cite_note-1

 

So allergens > proteins  >  biochemicals  >  4th dimension ? ( Seems to be currently most haccp popular.)

(oversimplification of course - not all proteins / biochemicals are allergens )

 

Maybe try this discussion for further dimensions courtesy FSMA  -

 

http://www.linkedin....193.S.225290426

 

Personally i suggest biochemicals are a subset of "chemicals" but biologists might disagree.

 

Then again haccp  "hazards" are also related to the type of harmful effect ?

 

Rgds / Charles.C

[teodymayojr]

MMM I classify allergens as allergens!

 

In my HACCP, I have Chemical, Microbiological , Physical & Allergen (clause 2.7.1  of BRC V6 & Clause 5.2 of BRC V6)

 

Not sure about other standards

 

Caz x

 

 

We came across with similar auditor. We now classify them as Allergen since we are BRC v6. 

[shea quay]

Anyone else call these intrinsic hazards? Handy catch all for "other" issues such as the over-addition of preservatives (not really chemical, more legal) and something to do with strawberries (I'll have to dig out my course notes for that one). 

[KTD]

So, are we defacto created a new hazard category of 'allergens' by not putting them into one of the existing Codex categories? Has anyone already done this and been through BRC or SQF certification - any issues or questions?

[jenky]

We have completed 2 SQF certification audits - successfully - and neither auditor questioned or commented on the classification of allergens as a chemical hazard.  We have both FDA and USDA regulated HACCP plans, have always classified allergens as chemical hazards, and have never received any questions from either regulatory agency. 

[cazyncymru]

We've done BRC and have them classified as allergens

[FBQFS01]

We just had an HACCP training by a US colleague and he stated that allergens have to be classified as chemical. If i look to auditors I had come in over the years (and also just recent) they expect allergens to be claffified als allergens.

[Shyguy77]

A few years ago in preparation for BRC and FSMA we added Allergens to our HACCP plan in its own catagory. Prior to this we had allergens listed in the chemical catagory on our HACCP plan. We have been BRC certified now for the past 4 years and it hasnt been an issue.

[Wine Gum]

We are also BRC certified and have included Allergens in its own category in the HACCP plan. Auditors seem fine with that.

[KTD]

Well, sounds like we have a divided house with no clear direction. Thanks for all the feedback...

Keith

[Sandima]

Interesting discussion.  Currently the CFIA defines allergens as a chemical hazard and we have been BRC certified three times with no questions.

 

I don't read the standard as 'requiring' it to be listed separately but as long as the hazards are identified and controlled under BRC it shouldn't matter which way you do it.

 

Sounds like at the moment it is auditor specific but likely the way of the future.

[Katja]

we have been audited sqf level 2, 3 times and classify allergens as chemicals.  We are currently not USDA but look to be in future and am wondering if i should change while i can.  Technically speaking nothing changes other than paperwork! Interesting topic to follow.

thanks

[Charles.C]

we have been audited sqf level 2, 3 times and classify allergens as chemicals.  We are currently not USDA but look to be in future and am wondering if i should change while i can.  Technically speaking nothing changes other than paperwork! Interesting topic to follow.

thanks

Dear katya,

 

Most (all?) private standards reference Codex (and/or NACMCF) for haccp "things" or the local legislation (priority 1).

 

AFAIK, Codex / NACMCF don't care. (because they are generic )(and Old).

 

But if CFIA do dictate in Canada, post #15 (1st para.) seems to answer yr query although perhaps not necessarily as per 2nd/3rd paras.

 

Seems improbable that  USDA (haccp) legislates for Canada ?

 

Rgds / Charles.C

[Katja]

you are correct, USDA does not dictate to CFIA however we all follow the same trends and I don't believe that it says anywhere in the CFIA food safety enhancement program that allergens MUST be categorized with chemicals.  Most inspectors realize that as long as you control them adequately you can call them anything you like and will often defer to the more rigid rules of GFSI.

Its more something to consider next time I review our plans.

[Charles.C]

Dear katya,

 

As you say, looks like some validation is required. Perhaps for the inspectors also ?.

 

the more rigid rules of GFSI

 

Not too sure about the "rigid" ?

 

More validation required but i predict that GFSI  is happily unconcerned regarding present topic.

 

Rgds / Charles.C

 

PS -actually i thought that "Health Canada' was responsible for legislation but only guessing.

 

PPS - i noticed this document which somewhat supports chemical but doesn't prove there is no haccp option

 

 fs_17.pdf   381.48KB   52 downloads

[genebartholomew]

I am having a lot of trouble thinking there needs to be discussion here. Allergens are proteins. Proteins are chemicals. Period. Chemical hazards. Sometimes you create more trouble for your self if you think an auditor has all of the right answers just because he/she is an auditor. TAke it up with the certification body abd teach this auditor a thing or two. 

[moskito]

Hi all,

 

we have classified allergens in a separate class (biological, chemical, physical). But in principle you always have a certain standpoint/view on things:

microorganisms -> biological hazard (what is the actor -> the microorganis or products thereof?)

virus -> biological hazard like Norovirus or HP A in fruits (the virus itself is the actor)

disinfectant -> chemical

pestizides -> chemical

metal -> physical

toxins of microorganisms -> chemical (type -> action) or biological (source)?

ethanol as disinfectant poduced by yeasts -> chemical (type) or biological (source)?

 

In my opinion definition is more or less the philosophical part, but as long you have included in the risk assessment these hazards and have taken measures.

 

Rgds

moskito

[Charles.C]

I am having a lot of trouble thinking there needs to be discussion here. Allergens are proteins. Proteins are chemicals. Period. Chemical hazards. Sometimes you create more trouble for your self if you think an auditor has all of the right answers just because he/she is an auditor. TAke it up with the certification body abd teach this auditor a thing or two. 

Dear genebartholomew,

 

I rather agree with you as far as allergens are concerned but generalising requires some caution. Simplicity is an admirable concept but organisations have a habit of making their own rules / definitions where some specific benefit is seen. The benefit may derive, for example, from (A) a scientific convenience or (B) an intention to improve clarity.

 

Few examples of  (A,B)  –

 (A)

 Mycotoxin HACCP.pdf   570.56KB   37 downloads

And, more generally, “any toxin produced by microbiological organisms is also a biological hazard”

 HACCP, UNIDO.ppt   2.16MB   56 downloads

(also contains a neat summary of methods for grouping processes in haccp)

 

(B)

FSMA’s philosophy   -  

 FSMA - allergenic hazards.png   94.12KB   1 downloads

 FSMA - radiological hazards.png   51.16KB   0 downloads

 

FWIW, I did a mini-allergen search via Google as to implemented haccp categorisations. I estimate approx. Chemical/Biological/4^th Category as 90/2/8% respectively.

 

This allergen haccp topic has now popped up at least twice since 2005. One can also see some useful insights in the previous threads –

 

http://www.ifsqn.com...zard/#entry6374

http://www.ifsqn.com...sis/#entry48764

 

Rgds / Charles.C

 

PS - posted before I saw moskito's previous comments. Some similar thought processes.

[Tony-C]

 

I don't read the standard as 'requiring' it to be listed separately but as long as the hazards are identified and controlled under BRC it shouldn't matter which way you do it.

 

 

Yep that's my take on it as well.

 

BRC Gudiance 2.7.1 List of potential hazards does state that 'the list shall include biological, chemical allergen and physical hazards' but does not prescribe that a separate category is required for each.

 

Regards,

 

Tony

[Charles.C]

Yep that's my take on it as well.

 

BRC Gudiance 2.7.1 List of potential hazards does state that 'the list shall include biological, chemical allergen and physical hazards' but does not prescribe that a separate category is required for each.

 

Regards,

 

Tony

 

Hi Tony,

 

I guess the USFDA (and USDA?) may disagree ( > FSMA?). Latter bodies seem rather opaque organisations.

 

Rgds / Charles