2 replies to this topic

[Weebus90]

Hi Everyone, 

We are looking to do specific allergen residue testing instead of overall residue protein testing. 

We currently re-pack trail mixes and fruit and nut mixes with a variety of different allergens in each. 

I know i need to conduct a validation study, and i'm planning on doing it for a month. 

During changeovers i will be doing a swab for each allergen contained in the product ensuring all proteins are removed. 

Once i do this for a month, and validate that each and every time we clean, it is effective at removing the allergen proteins, how would i go about cutting down and only doing 1 or two swabs per product, instead of all allergens?

the swabs we are using have different ppm levels they detect of each. 

Would it be possible to validate the cleaning and then only swab the lowest detectable allergen out of the group?

 

Thanks

Weebus

[Tony-C]

Hi Everyone, 

We are looking to do specific allergen residue testing instead of overall residue protein testing. 

We currently re-pack trail mixes and fruit and nut mixes with a variety of different allergens in each. 

I know i need to conduct a validation study, and i'm planning on doing it for a month. 

During changeovers i will be doing a swab for each allergen contained in the product ensuring all proteins are removed. 

Once i do this for a month, and validate that each and every time we clean, it is effective at removing the allergen proteins, how would i go about cutting down and only doing 1 or two swabs per product, instead of all allergens?

the swabs we are using have different ppm levels they detect of each. 

Would it be possible to validate the cleaning and then only swab the lowest detectable allergen out of the group?

 

Thanks

Weebus

 

Hi Weebus,

 

You might want to do some bedtime reading!

 

EFSA Scientific Opinion on the evaluation of allergenic foods and food ingredients for labelling purposes
12. Allergen risk assessment and determination of “thresholds” for allergenic foods/ingredients
Page 63 12.6. Conclusion
Different approaches have been proposed for allergen risk assessment, which may be used to inform risk management decisions for allergen labelling. The reliability of the risk estimates will depend on the type, quality and amount of data used, to estimate both population thresholds (or threshold distributions) and exposure to the allergenic food/ingredient. The purpose of the risk assessment (e.g. exemptions from labelling, labelling of allergens unintentionally present in food) and the level of risk that may be acceptable (e.g. the fraction of the allergic population that it aims to protect and to what extent) are risk management decisions, which are outside EFSA’s remit.

 

So not much commitment there but Appendix A. has Population thresholds calculated for some allergenic foods/ingredients

 

Here are some indications of threshholds:

 

http://www.foodaller...islation_uk.pdf

 

http://www.fda.gov/F....htm#table-iv-5

 

You will no doubt have a lot of data for comparison and may be able to answer this question yourself from this data.

 

You will need to consider factors to achieve less than NOAEL for each allergen in your products after clean. This will depend on many factors including consumers, recipe, form of nuts, local legislation, differences in removing nut residues. If you can demonstrate that one swab of one allergen type is likely to measure the highest risk of contamination of the next product then I can see this being possible.

 

My concerns would be 'traps in your equipment' such as where a piece of nut is not removed during the clean and becomes dislodged into the next product, but I'm sure this is something you have looked at.

 

Regards,

 

Tony
 

[Charles.C]

Hi Weebus,

 

I suspect, from any auditorial POV, you are going to end up with a conceptual decision between "zero tolerance vs Risk Assessment" for a hazard regarded as "likely to occur" in the raw material and a process without an "elimination" step. The former usually prevails. 

 

There are vague analogies to the risk-based proposals by VITAL for allergen labelling options. Almost zero take-up globally from a regulatory POV -

http://www.foodaller...Guidelines.html

 

I presume yr current labelling includes (and will continue to include)  'may have' traces of allergen ABCDE..X.