5 replies to this topic

[LoredanaM]

Hi all,

 

I need help figuring out the proper and 'perfect' allergen program in a cold environment (fish processing). The process is simple: to a fillet of fish (salmon, sole) is added a certain quantity of feta cheese stuffing or seafood (shrimp based) stuffing (the two stuffing are received as a "finished product"). The two stuffing have as declared allergens  egg, milk, wheat (feta cheese one) and soy, shellfish, egg, milk, wheat (seafood one). They come in sealed buckets and each bucket is in a master case.

 

We were required last year at the BRC audit to segregate the area with minimum curtains, but talking with knowledgeable QAs, their answer is that segregating the area with curtains doesn't do anything for allergen control.

 

Does anyone here have experience with this program in a cold environment and what would be the best practice for food safety concern (also, it has to be feasible to handle by a small production crew).

 

If you need more details do not hesitate to let me know ... I am not a microbiology background professional and I try to learn the best practices that can be explain in simple terms to employees (so is to become a proper habit in handling allergen containing products) and have the proper answers (studies back-ups) when talking with auditors.

 

 

Thank you,

 

Lori

[xylough]

Hi Lori,

 

I cannot speak to BRC requirements, however I have a successful allergen control program at a USDA meat and poultry further processor. Similar to you we have multi-allergen marinades. The only thing unique to a refrigerated processing room that strikes me from experience is that allergens can easily contaminate the evaporator units that chill the room with all the high velocity air movement. Especially if any of your allergens are in powdered form. Studies of how far allergens may cause contamination of air, equipment in nexus to the immediate allergen work area may be indicated. Investigation of allergen contamination of the coils and fins in the evaporators may be indicated.

When you say "allergen control" I think of all the many essential  aspects of an allergen control program:

Receiving - are allergens commingled on the delivery vehicle? Is there a documented label review of allergens against current manufacturer specifications of the allergenic incoming goods? Is there an identification, hold, sequestration and approval process for allergens?

Storage - Is there an allergen storage program that address ID, proper storage for sequestration, spill clean up in storage areas, authorization for access and transfer to the processing room

Processing - a written plan that addresses timing (scheduling) and proximity (here is where strip curtain could possibly play a role) with respect to cross-contact, verification of allergen sanitation, change-over processes and documentation between allergenic, different allergenic and non-allergenic runs, labeling while products are still in-process, protective controls for personnel and their uniforms, hair nets, utensils (anything that may become contaminated during an allergenic run)

Packaging and Labeling - cross contact, label review and approval

Finished product storage - nearly dito to incoming ingredient storage.

 

Attached are some recent white papers on allergen control

 

Regards

Attached Files

•  _ News _ Food Safety Tech.pdf   102.64KB   43 downloads
•  3894.pdf   4.06MB   44 downloads
•  89246-allergen-control--using-techniques-that-go-well-beyond-the-label.pdf   105.66KB   54 downloads
•  93463-cleaning-is-more-important-than-ever.pdf   46.77KB   41 downloads
•  Allergen Labelling Technical Guidance FSA (1).pdf   693.51KB   38 downloads
•  Allergen Management Through Environmental Monitoring.pdf   4.08MB   48 downloads
•  Allergen Management_ Challenges and Trends - Food Safety Magazine.pdf   826.65KB   37 downloads
•  allergen_ebook.pdf   927.16KB   43 downloads
•  Allergen-Guidance-Document.pdf   88.61KB   44 downloads
•  Allergy - what to consider when labelling food - a guide FSA.pdf   281.5KB   29 downloads
•  Allergens WP.pdf   1.29MB   45 downloads
•  Food Allergen Management in the Real World.pdf   2.46MB   41 downloads
•  TraceGains-Allergen-eBook-6-Best-Practices.pdf   771.44KB   41 downloads
•  Global Perspective on Food Allergens.pdf   1.07MB   39 downloads
•  SGS-White Paper-Allergen Management-EN-April 2014.pdf   891.76KB   46 downloads
•  FINAL_Allergen_A4_web.pdf   3.23MB   50 downloads

[Charles.C]

We were required last year at the BRC audit to segregate the area with minimum curtains

LoreDanaM,

 

As per yr invitation/previous post -

 

Can you clarify the reason given by the BRC auditor for the above suggested modification ?. I anticipate that it was to prevent a specific hazard (or >1), ie contamination from "something", adjacent process lines with no allergen problems perhaps. Afaik, potential allergenic cross-contaminations are not particularly activated/de-activated by cold itself.

 

The general approach to ingredient-allergen control requires a system-wide  program as previously uploaded here (which i suggest you should implement anyway [in fact I'm surprised the auditor did not request it]).

[trubertq]

Start with a risk assessment... take your flow diagram and at each step assess the probability and severity of cross contamination. I see you have multi allergens and so your labelling is crucial. I would also agree with Xylough , if you have positive air pressure or Air con controlling the temperature in the room you must assess the risk of allergens contaminating the air circulation system. Other than that, as Charles has said, Allergen control is a system wide program. I am attaching a good document from The UK Food safety Authority.

Attached Files

•  Guidance on Allergens Management & Consumer Information - FSA.pdf   672.19KB   45 downloads

[jel]

Hi Lori,

 

I cannot speak to BRC requirements, however I have a successful allergen control program at a USDA meat and poultry further processor. Similar to you we have multi-allergen marinades. The only thing unique to a refrigerated processing room that strikes me from experience is that allergens can easily contaminate the evaporator units that chill the room with all the high velocity air movement. Especially if any of your allergens are in powdered form. Studies of how far allergens may cause contamination of air, equipment in nexus to the immediate allergen work area may be indicated. Investigation of allergen contamination of the coils and fins in the evaporators may be indicated.

When you say "allergen control" I think of all the many essential  aspects of an allergen control program:

Receiving - are allergens commingled on the delivery vehicle? Is there a documented label review of allergens against current manufacturer specifications of the allergenic incoming goods? Is there an identification, hold, sequestration and approval process for allergens?

Storage - Is there an allergen storage program that address ID, proper storage for sequestration, spill clean up in storage areas, authorization for access and transfer to the processing room

Processing - a written plan that addresses timing (scheduling) and proximity (here is where strip curtain could possibly play a role) with respect to cross-contact, verification of allergen sanitation, change-over processes and documentation between allergenic, different allergenic and non-allergenic runs, labeling while products are still in-process, protective controls for personnel and their uniforms, hair nets, utensils (anything that may become contaminated during an allergenic run)

Packaging and Labeling - cross contact, label review and approval

Finished product storage - nearly dito to incoming ingredient storage.

 

Attached are some recent white papers on allergen control

 

Regards

Thanks you for the information

[LoredanaM]

Hi all,

 

Thank you for your feedback. There is an allergen program in place - all we have is a cutting board table that is dedicated for that purpose only, and after the stuffing is added to the fillet, is rolled up and then portioned in smaller sizes. The stuffing per say is cream base (so no powder, liquids). Each individual portion has a label that indicates the allergens and also the method of storage and cooking; the finished product is not Ready-To-Eat, and the production room is temperature controlled.

 

Xylough thank you for the reference material and the insight into the air flow cross-contamination probability. What type of allergen testing are you conducting for the evaporator unit? I use Hygiena allergen swab (Aller-Snap) for food-contact surface only.

 

Charles, the reason the auditor gave for the finding was that is not enough separation between work areas (I suggested to the Management prior to the audit to create a visible separation of the area - of course being there for only few weeks my suggestion was ignored); the issue that I have now is that the curtains that are already installed do not really separate the allergen area.  

 

Trubertq thank you for reference material - in regards to flow diagram, it is under review and all your help is more than welcomed :)