The only allergen I have to deal with is sulphites. I work in a fruit juice/concentrate manufacturing factility. Not all of our products contain sulphur. I validate the process by the following procedure
1. Product with sulphites if packed out
2. Then Cleaning and Sanitation conducted
3. Next product without sulphites is blended.
4. Collect product from the very begining of the process, ie. first bottle off the line or first concentrate being packed off.
5. Conduct a Sulphur test (we do this by titration) on the product. This confirms absence/ presence of sulphur. If present the clean in inadequate.
Hope this helps.
Yes I like this providing your test methods is sensitive enough. You could also test the final rinse water.
Under EU law: Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers:
12. Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers;
Sulphite Test Kit
As I'm going to explain below SQF don't like it so much for validation of cleaning due to dilution by the product but for me if your first off product is clear then there is a high confidence in your clean. The problem arises with equipment which is more difficult to clean and has 'traps' where allergen could possibly accumulate.
Or should one validate each allergen used in a facility and its removal?
Please help. Just wondering if my logic is sound or absolutely broken.
Here are some extracts from SQF Guidance on Validation of 'Allergen Cleans' that you might find useful:
The purpose of validation is to prove that the cleaning process employed is effective in removing the allergen of concern. This proof requires evidence that the specific allergen was in fact removed, or reduced to an acceptable level by the cleaning procedure. Therefore, only an allergen specific test will provide that evidence.
When there is a mixture of different allergens in use, the acceptable method for confirming the thoroughness of cleaning is to test for the highest risk allergens, the highest concentration allergens, or the ones that are most difficult to remove. Examples of difficult to remove allergens include milk proteins, such as in chocolates or caramels, and cooked eggs. In some cases, a supplier may choose to test for an allergen protein which is lower in concentration.
Finished product testing is not sufficient by itself to validate cleaning methods since any allergen present is diluted by the product and can become nearly undetectable thus rendering a questionable result. However, finished product testing can be useful when an allergenic ingredient might be mistakenly added to a product during the manufacturing process. Extensive finished product testing conducted in conjunction with visual inspections of operating equipment may provide the evidence that the allergen removal verification method is working. Further evaluation on a case by case basis may be needed in some of these situations.