Allergen Policy in Packaging
Hi, we had a customer audit last week (we make food contact plastic packaging) and they gave us a major NCR for not having an allergen policy. Part of our HACCP risk assessment includes allergens only relating to food brought in by staff. He wants us to risk assess raw material, lubricants, cleaning chemicals, pest control baits, other solids, liquids or powders, workwear and laundry facilities.
Can anyone help with either a suitable policy or risk assessment starter for 10 in a similar industry please? It seems a bit OTT and BRC haven't failed us for it.
We do Paper board containers and have not had an issue with any of our audits. I have the same thing stating only foods brought in by employees are allergens. We did do an assessment on all of our raw materials and none are an allergen. I do have it stated in our Allergen program that this will be reviewed with any new raw materials and/or on a yearly basis.
We make secondary packaging sleeves (from folding box board) . We have always checked out our oils etc for allergens. (Some are ground nut oils) We have a customer who wanted and Allergen policy and to ban NUT for site. This would mean specifying the contents of the vendors and controlling staff lunches. We have put together the below policy but refuse to ban nuts. It will be too difficult to manage. We re-trained all our staff on allergen awareness and hand washing.
NUT POLICY
XXXXX are aware that nut allergies have a great potential to be life threatening and nut cross contamination is considered in the annual HACCP risk assessment review.
XXXXXX operates a quality management system in line with BRC/IOP Global Standard For Packaging And Packaging Materials. This includes hygiene practices such as hand washing before entering production, daily overall changes, and prohibition of eating and drinking in the production and storage areas, designated/segregated colour coded cleaning equipment which is not transferred between areas.
In addition to the above good manufacturing practices, XXXXX have taken the following management steps and precautions to reduce the risk of nut cross contamination to our packaging.
- Nuts and nut derivatives are not used as an ingredient in our products.
- All maintenance materials such as lubricants, grease, cleaning materials, paints etc. are nut free. This is controlled at purchasing, through COSHH information provided and monitored through GMP/ Internal audits.
- All visitors & contractors complete a hygiene questionnaire which includes instruction in our control of food and drink in production and storage areas.
- At induction all staff are given hygiene training this will now include allergen awareness training. Any pre-existing staff will be trained on allergen awareness.
- Hygiene refresher training, including allergen awareness, will be given to all staff annually.
- Allergen posters are displayed in the staff facilities as a constant reminder.
Signed :
Position: Date :
Regards
Sharon
Thank you both. Very helpful information provided.