Including Allergens in Hazard Analysis?
I've done an ample search and haven't quite found what I'm looking for. We are having a bit of a debate, and I'd like some other viewpoints.
We are a gluten free facility. We bring oats in from our own fields, and process it into various products.
Should we list allergens at EVERY step of the process as a potential risk (we do testing when oats arrive in the field and finished product testing).... or simply at the first step?
The thought was: if an employee were to abandon all rules and bring food into the facility, there lies contamination risk. Very unlikely, but if it DID happen- the consequences could be huge (if testing were to fail/be missed somehow and the product shipped out contaminated).
So do we put allergens on the hazard analysis for that step even though we have GMPs and PRPs in place to prevent it from happening, and that is the only possible way for an allergen to be introduced at that point? Including allergens changes whether that step is significant or not.
In short the answer is yes.
Write out your HACCP with four risks...five if you want to include radiological.
Biological
Physical
Chemical
Allergen
Some auditors even ask to pull out allergen all together and make a risk analysis at every processing point using allergens.
Here's another thread on the topic...but mind you towards the end it starts to get a bit off topic :off_topic:
At our plant we have a look at the following hazard groups:
microbiological
chemical
physical
allergens
and nutritional hazards
We added allergens and nutritional hazards, because we are producing baby food and these hazard might have a huge impact!
example for nutritional hazards would be over- /underdosage of minerals or other components that might lead to underweight/ brain damage etc. Its really important, because our product can be the only source of nutrition!
Regarding allergens we had a detailed look at all allergen groups especially regarding cleaning procedures and raw material management.
Yes, I have included allergens in every step of my risk assessment.
However, I do then have a separate allergen programme and on this I assess the raw ingredients and finished products. If we add a similar product, it easier to change (and I don't strictly need to have a HACCP review) I also have a allergen improvement plan.
With regards to employees, in your case how do you handle sandwiches / pasta etc that contain gluten? you will need to document this and ensure its rolled out to your staff by training
Caz x
mhmm regarding homemade food by employees we have a peanut-free policy, because thats one big allergen hazard for us.
So nobody is allowed to take peanut containing products on the company area at all (its included in every employment contract and even sub-contractors and visitors are included).
Regarding gluten... obviously you can´t prohibit the consumption of bred, noodles etc...
As we are a gluten free company as well you have to make sure, that the probability of contaminating your product with gluten is really low.
In our case eating in production area is prohibited. So employees are only allowed to eat in designated areas, that are outside production. Additionally employees have to change clothing when leaving production area and of course handwashing etc. So the probability of introducing gluten to production area via clothes etc. is really low.
Moreover it might be usefull to set rules for the frequency of giving the working clothes to cleaning.
We only have one adulterative allergen that we look at and that's Soy. We only placed it at receiving because our hazards are listed only in the steps that they are potentially introduced into the system or when they are mitigated. I've seen HACCP plans where a hazard flowed through the entire hazard analysis from when it was potentially introduced to when it was mitigated.
I believe the real answer is: It depends on how you want to write it and can you defend what you wrote.
For some reason more often than not I've been finding, especially with the Hazard Analysis, that there is almost never a concrete answer to whatever you want to ask.
For some reason more often than not I've been finding, especially with the Hazard Analysis, that there is almost never a concrete answer to whatever you want to ask.
You are right :) Very well described :D
Also don't let that stop you from asking though. You at least get ideas of what other people are doing.
I had asked a question about performing the likeliness and severity risk assessment if it should be before or after you take into account the mitigating programs and equipment and I got about a 50/50 split of each... so I gave up trying to figure out what was right.
Yes include it at every step and yes have a full allergen control programme lined out as Caz said with the risk assessment of allergen introduction at every step of your process.
Furthermore, review this annually and make sure to sign and date the review!!
I have a client whose primary products are allergens (crustaceans and molluscs) and the twist in the tale is the bait for one is carcasses of the other , risk assess that and come up with a definitive control!!
Yes, I have included allergens in every step of my risk assessment.
However, I do then have a separate allergen programme and on this I assess the raw ingredients and finished products. If we add a similar product, it easier to change (and I don't strictly need to have a HACCP review) I also have a allergen improvement plan.
With regards to employees, in your case how do you handle sandwiches / pasta etc that contain gluten? you will need to document this and ensure its rolled out to your staff by training
Caz x
mhmm regarding homemade food by employees we have a peanut-free policy, because thats one big allergen hazard for us.
So nobody is allowed to take peanut containing products on the company area at all (its included in every employment contract and even sub-contractors and visitors are included).
Regarding gluten... obviously you can´t prohibit the consumption of bred, noodles etc...
As we are a gluten free company as well you have to make sure, that the probability of contaminating your product with gluten is really low.
In our case eating in production area is prohibited. So employees are only allowed to eat in designated areas, that are outside production. Additionally employees have to change clothing when leaving production area and of course handwashing etc. So the probability of introducing gluten to production area via clothes etc. is really low.
Moreover it might be usefull to set rules for the frequency of giving the working clothes to cleaning.
We actually do prohibit gluten products on our premises. We tell everyone from the minute they walk in the door looking for an application to apply, again during interviews, and again during orientation. We are very strict as our market is for those who experience reactions to the smallest amount of gluten. We do not allow food in the production area, require washing hands at the sink in the office area and then again in the production area (and I am still working on convincing others that it's in our best interest to purchase smocks or lab coats or uniforms that won't have the potential to be contaminated) , but the question came up about "what if".
Thank you everyone, this is exactly what I needed. Sometimes it's nice to bounce ideas around with people who actually care about the safety of food and don't just think it's all nonsense that they have to play along with ;)
I think, due to the nature of our facility, I will not put it at all steps, because the grain itself is tested after it arrives. After that, the only chance for contamination is a worker going against EVERYTHING they've been taught, and that's highly unlikely (and since it changes the risks for that step greatly)... but I will put it at the final packaging stages, where we do final product testing, just to catch any mishaps.
We actually do prohibit gluten products on our premises. We tell everyone from the minute they walk in the door looking for an application to apply, again during interviews, and again during orientation. We are very strict as our market is for those who experience reactions to the smallest amount of gluten. We do not allow food in the production area, require washing hands at the sink in the office area and then again in the production area (and I am still working on convincing others that it's in our best interest to purchase smocks or lab coats or uniforms that won't have the potential to be contaminated) , but the question came up about "what if".
Ah now you have stepped into another realm of risk assessing. :giggle:
This should be included in your VACCP/TACCP study. :roflmao:
Caz x
We actually don't have a VACCP/TACCP plan... I don't think these are as common in the US? I've only seen about them on here, but have never heard of them in my implementing SQF course or any of my food safety and sanitation courses (granted, those were also 4 years ago)
I have a feeling it is just a matter of time before we see them more often in the states.
I agree, it seems a lot of other countries have jumped ahead on this and we're just playing catch up. We did run into some issues with shipping to a client of ours this year (the only exporting we do, happens to this one customer once a year), because their country had changed their food safety requirements and documentation since we last shipped.