Should allergens be included in the HACCP plan?

Hello everybody,

I am currently working in a company producing dairy & gluten-free products, I have just started and when revising I have realized that in their HACCP plan they do not include allergens (being gluten & dairy related the most critical). They have told me that they include in an allergen control plan, is that right or they should be included in the HACCP as well?

Thanks for your help!

Yes, generally they are found in a HACCP plan and are considered a hazard

Hello everybody,

 

I am currently working in a company producing dairy & gluten-free products, I have just started and when revising I have realized that in their HACCP plan they do not include allergens (being gluten & dairy related the most critical). They have told me that they include in an allergen control plan, is that right or they should be included in the HACCP as well?

 

Thanks for your help!

The risk of allergens must be evaluated in the risk assessment phase of the HACCP Plan.  Your allergen control plan tells how you control that risk.  So the allergen control plan needs to be part of your HACCP Plan.

Martha

Hello everybody,

 

I am currently working in a company producing dairy & gluten-free products, I have just started and when revising I have realized that in their HACCP plan they do not include allergens (being gluten & dairy related the most critical). They have told me that they include in an allergen control plan, is that right or they should be included in the HACCP as well?

 

Thanks for your help!

Dear LPali,

You omitted to mention whether yr haccp system is certified to any particular standard. This could be relevant.

AFAIK, many people define their Allergen Control Program to be a Prerequisite (eg as per iso2002-1). Then reference this against occurrence of allergen hazards within the hazard analysis.

Logically, if a particular allergen is intrinsic to the input material, haccp  control is only possible through labelling.

Rgds / Charles.C

Hello everybody,

 

I am currently working in a company producing dairy & gluten-free products, I have just started and when revising I have realized that in their HACCP plan they do not include allergens (being gluten & dairy related the most critical). They have told me that they include in an allergen control plan, is that right or they should be included in the HACCP as well?

 

Thanks for your help!

The answer is Yes. I would put it under chemical.

However, I recently had an auditor that wanted a HACCP based structure on an allergen risk analysis separate from the HACCP: in the dock door through storage through processing to finished product to being shipped just as you would with HACCP.

Definitely! Allergens can be identified as a chemical hazard although the modern thinking is to have allergen identification and assessment as their own category. The majority of certification standards require all raw materials to also be identified and assessed for allergen status.

I make reference to allergens, as a separate entity and not as a chemical contaminant, in my HACCP.

I then have a series of separate allergen documents, including ingredient & final product risk assessments, a (potential) cross contamination risk assessment. Specific handling procedures etc, which builds up my allergen plan.

To be honest, in my case its a total waste of time...I only have 1 allergen, and it's in everything! lol

Caz x

We have no allergens in any of our raw materials.  We have an allergen control plan, because we still need to prevent allergens from entering the product stream through worker contamination.  We forbid any food from being near the production building (separate from the building with the lunchroom) and require workers to wash their hands after meals.  That is also important to the sanitation plan, but it is our only line of defense from protecting the product from allergens.  Having the allergen plan in place is never wrong.

Martha

Thanks for your comment.

Yes, specific allergens must be included in a HACCP plan and are considered a "Chemical" hazard.  You would control the hazards with your Allergen Program so there would also be some mention of the allergens within the Allergen Program itself.

No, allergens are covered in your GMP's and if done so properly are a controlled hazard. That is, the known wheat allergen does not come from the environment or a process but, rather is inherent to the ingredient and cannot be reduced or eliminated by a process because the chemical is part of the ingredient such that it will be present in the finished product testing every time (unlike E. Coli. in beef which can be eliminated or reduced in the final product). I would identify the allergen as a regulated KNOWN hazard (I am sure there is plenty of scientific information) and as such is not a risk but a known hazard in HACCP that is controlled by GMP (storage and scaling) and labeling requirements to protect the end consumer. With that being said, you will still need to prevent contamination of non-allergen products by cleaning between products and scheduling of runs.

I make reference to allergens, as a separate entity and not as a chemical contaminant, in my HACCP.

 

I then have a series of separate allergen documents, including ingredient & final product risk assessments, a (potential) cross contamination risk assessment. Specific handling procedures etc, which builds up my allergen plan.

 

To be honest, in my case its a total waste of time...I only have 1 allergen, and it's in everything! lol

 

Caz x

Caz x, I find it interesting that you have an uncontrollable allergen that is found in everything and have to control separate allergen documents, including ingredient & final product risk assessments, a (potential) cross contamination risk assessment. Specific handling procedures etc.

I would agree with Martha that a program still must exist, just for allergens entering the product stream through worker contamination since they'll eat something with allergens. But to have a risk assessment on an allergen that's in everything just to say it says it on the final product label?

The allergen risk should be listed in your HAACP plan and your allergen control plan should be listed as the control for the allergens.  Your HACCP plan has to address all food safety risks and their control plans - incoming materials, processing, packaging, storing, shipping, exterior, etc.  This is the core of your risk analysis and control evaluation which HACCP requires.

IMO allergens should be included in your process hazard assessment with PRP's being the control. But you need a solid validation (at least annually) that you equipment cleaning effectively cleans your various allergens in all non-dedicated equipment using multiple allergens, and if you regularly change products with different (or no) allergens that you have a sequential scheduling scheme that effectively allows for effective control (ex. after a wet wash start with a product with no allergens, next perhaps a dry clean with a product with one allergen - say soy, another dry clean and a product with soy and eggs until you need to run product with no allergens whereupon a wet wash would start a new sequence. It's probably a good idea to include where (and which) various allergens come into your processes on your HACCP flow charts.  

Lol RG3, I should explain....I work in a dairy!!!


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A dairy with no egg nog?!

What do you do with all your brandy?

Turn it into Brandy Butter!! :silly:

Having completed a Level 6 HACCP training course earlier this year, Allergens are the 4th hazard after Biological, Chemical and Physical. 

That's the way I do it with all my clients and of course like Caz I have the ancillary allergen programme for the different allergens in the different companies.

Having completed a Level 6 HACCP training course earlier this year, Allergens are the 4th hazard after Biological, Chemical and Physical. 

 

That's the way I do it with all my clients and of course like Caz I have the ancillary allergen programme for the different allergens in the different companies.

OMG I am so glad that someone has done something more than a level 4!

I did Level 7 Global Food Safety (basically HACCP) and Global Food Safety Systems as part of my MSc. Yet very few believe there is anything beyond level 4!

So well done trubertq!

Caz x

I'm not quite sure how our FETAC levels compare to yours Caz but I think this is as far as I can go professionally with HACCP unless I decide to do a Post Grad, and frankly... I am too old and life is too short....

Of course there will always be refresher training, depending on location and the quality of the hotel!!

As a side note, the Food Safety Enhancement Program (fsep)  in Canada (using a HACCP system) list Allergens as their own prerequisite program and as such require a program separate from biological, chemical or physical contamination. The most recent training video produced by the Canadian government also lists allergens as a 4th contaminate which must be controlled. I agree with PP, make sure you are clear on the standard you are working against as it may be lumped together with other hazards, or as in my case, its own category.

Yes - majority of food safety courses now teach that there are 4 types of hazard, micro, physical, chemical & allergenic. Certainly if you are working towards BRC certification, the requirement is that the HACCP assessment considers allergens.

Yes - majority of food safety courses now teach that there are 4 types of hazard, micro, physical, chemical & allergenic. Certainly if you are working towards BRC certification, the requirement is that the HACCP assessment considers allergens.

Dear babsbesafe,

Thks for yr input and Welcome to the (posting) Forum  :welcome:

TBH, the consensus IMO is probably that it's (4)  just a matter of opinion. :smile:

Rgds / Charles.C