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Allergen Changeover Big 8 Changeover Matrix

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Tomato

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Posted 04 October 2014 - 07:51 PM

Hello,

 

Is there a consensus on how to handle changing over between allergens in a hierarchal sense? Such that if a line is currently producing an almond product and the next product is a macadamia product. That would mean the line would only need to be washed out instead of requiring a full foam cleaning between the products. But if the line is changing from macadamia to almond then it would be foamed as if going from a peanut product to a sugar product.

 

 

I have a plant were QA is wanting to have products made in this order from least to highest risk. Going down the list is washing out but going up is foaming.

1 Almond/ Pecan

2. Macadamia

3. Peanut

 

But their production is wanting to do the following because it is faster.

 

1. Almond/Pecan/Macadamia

2. Peanut

 

Is there any help for this?



Charles.C

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Posted 05 October 2014 - 06:26 AM

Dear Tomato,

 

Interesting query.

 

Other than peanut, the items appear to all be “tree nuts” (as per FALCPA, Big 8 list).

 

Don't quite understand the risk basis of yr up-down methodology as described, eg seems you are somehow ranking within tree nuts ?. Perhaps you can clarify.

 

However  perhaps yr local Regulatory Labelling rules may also directly/indirectly, rightly/wrongly, influence the processing sequence ?  (eg do you label all 4 as "may contain tree nuts/peanuts :smile:  or ?)

http://www.foodaller...ree-nut-allergy

http://farrp.unl.edu/FoodLabeling

 

examples of some typical, probably USA, change-over matrices are here -

 

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

 

(seem to not 100% support either of your propositions ! :smile: )

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


Mike Green

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Posted 05 October 2014 - 01:55 PM

I don't have any experience of running different allergens on the same line-& so I guess I just assumed that a 'clean-down was a clean-down' ie removing enough of the protein to make it safe for those with an allergy?

 

I don't understand at all how some allergens need a 'less thorough' clean'?

 

 

I am aware of individuals who have a specific tree-nut allergy but still consume peanuts (& infact other tree-nuts!)- I am now wondering how this can possibly mitigate the risk (unless as Charles says, the products are all labelled 'may contain' )

 

Kind Regards

 

Mike


I may sound like a complete idiot...but actually there are a couple of bits missing

Tomato

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Posted 05 October 2014 - 03:17 PM

Hello,

 

Some people think that individual tree nuts should all be different and separate allergens and others think that a tree nut is a tree nut. I have no solid opinion on it but have been reading and thinking about this as a means of procrastination for an upcoming audit.

 

 

The up down list was a visualization aid given by the separate allergen party. Our changeover matrix goes from non-allergens to allergens, such that the farther down or right a product is on the matrix then the more allergen contact that line has been in since a foam cleaning. The idea is to keep moving down and towards the right when scheduling so that a sugar based product starts the week and an allergen product ends. Although it was arbitrary at first to list almond pecan instead of macadamia first, further research has since provided me with a different order. But the initial and still working idea is that a tree nut can go into another tree nut or peanut but 2 combined tree nuts cannot go back into one nut even if it is one of the previous two and peanut can only go into peanut. Meaning running a Macadamia product and then a pecan product is ok but then going back to macadamia is not ok.

 

Almond and pecan are on the same plane because we either run one or the other not both in the same week on the same line. We hardly make any almonds usually an order every other week of something like 8k lbs compared to orders like 35k lbs of pecan products or 50k lbs of macadamia every week.  They are both reported higher than macadamia specific allergies so I am going to propose that an order, if necessary, would be

 

 

Macadamia -> Pecan/Almond -> Peanut

 

All allegies are still high risk in the plant but because they are different and have different effects and rates etc, then they should be treated with extreme care still but differently from each other.  

As for some allergens needing a less thorough clean it just comes down to uptime. A foam cleaning takes 36-48 hours and another hour to check over and re sanitize while a washout between sku's takes 2 hours. Tree nuts into another type of tree nuts should be ok with a water wash out as is tree nuts into peanuts so long as you continue to increase the potential allergen count. Going backwards or going to no allergens would mean a full foam cleaning to remove all allergens. Ideally after every sku we would wash out and after every allergen sku foam clean but that isn't going to happen.

 

 

Our labels say may contain../run on equipment that ..., or contains ,,, or any combination of those.   


Edited by Tomato, 05 October 2014 - 03:39 PM.


Charles.C

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Posted 06 October 2014 - 03:14 AM

Dear Tomato,

 

Thanks for the frank response. Some interesting hypothesizing / refs (slightly old maybe). The idea of successively increasing allergen complexity to minimise cross-contamination is not new of course but the logic / use of validatory ref to justify the proposed routine eluded me. My lacking. :smile:

 

Some people think that individual tree nuts should all be different and separate allergens and others think that a tree nut is a tree nut.

 

 

Yes, precisely.

 

My previous posted link suggests that the the consumer viewpoint favours separating tree nuts. Hardly surprising i guess. And perhaps justified.

 

I doubt  that the concept of a clinically non-significant tree nut allergen is validatable except perhaps based on statistical incident data. But such a hypothesis  is presumably confounded by its presence in the US, Big 8 list. (other locations may well vary statistically).

 

It is unclear to me as to the exact power that  appropriate labelling wields in the context of  ones’s expected degree of rigor regarding cleaning activities, eg is the typical processor required to strictly minimize allergen cross-contamination regardless of labelling “coverage” ? I am guessing it will depend on the situation/product (this is discussed / illustrated in some detail in  2nd,3rd attachments below).

 

This UK official ref (2006, prob. now revised) suggests that labelling may be a substantial defence -

Attached File  alg 1 - FSA Guidance allergen management, 2006.pdf   619.9KB   81 downloads

(see Pg 11)(But also see current sec.7.2 of bottom link)

 

For US I noticed this comment,

 

The allergen advisory statement cannot be a substitute for poor GMPs. So, if cleaning is can be an effective solution, or if a change in ingredient sourcing prevents the use of an advisory statement, the company would be expected to choose those options. Also, there have been some proposals to add small quantities of non-functional allergenic ingredients to products made on shared equipment or in common facilities. By doing this, the miniscule addition could be included at the end of an ingredient declaration. This is an inappropriate practice if it is designed to circumvent cleaning that could either remove the allergen or at least minimize it to the point of warranting an allergen advisory statement. 

 

Attached File  alg 2 - Food allergen handling guidance, NCA.pdf   349.67KB   84 downloads

 

So far I have only seen one processor reference (2013) which contains a clear statement as to their approach regarding different tree nuts (inc. yr mentioned varieties)   –

 

Attached File  alg 3 - Allergen Management, 2013.pdf   5MB   119 downloads

(see pg 54/104)

 

(Hopefully yr auditor is procrastination-friendly, or other, tree nut neutral, examples also exist  :smile:  )

 

Regds / Charles.C

 

PS - slightly OT but i also noticed this interesting comment -

 

When applied prudently, precautionary labels can help protect vulnerable consumers. However the unwarranted use of precautionary labels can: i) result in the unnecessary elimination of healthy options from the diet of allergic consumers or ii) reduce their credibility causing vulnerable consumers to take risks with these foods. Regarding the latter, a study of British parents of children with nut allergy found that many either ignored warning labels on foods or assumed that the wording (e.g. 'not suitable for nut allergy sufferers 'versus 'may contain traces of nuts' etc) reflects a gradation of risk.

 

http://www.eufic.org...Food_Allergens/


Kind Regards,

 

Charles.C


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