7.1.4 - Allergen Awareness Training

Hi Everyone,

I'm new to this forum so still trying to get my head around locating information.  I was wondering if anyone else has run into the issue with section 7.1.4 in BRC regarding allergen awareness training.  I have just started working for a Game Meat Processing plant and we are trying to get our BRC accreditation.  We currently have no allergens being stored or processed on site, we have no allergen training or procedures relating to allergens in place.  My understanding of 7.1.4 is that all personnel should receive allergen awareness training however my team read this as allergen training is only required if allergens are handled on site.  Can anyone clarify if they have run into this situation?

Hi Casper13,

:welcome:

An interesting question. First of all I'm assuming that you are not making any allergen claims.

In order to decide what training is required you will need to consider the potential for allergen contamination, this will include
- cross contamination of raw materials at suppliers
- allergen status of maintenance materials such as lubricating oil
- potential contamination from bought in food or from catering facilities

BRC Standard 4.8 STAFF FACILITIES
4.8.10 Where catering facilities are provided on the premises, they shall be suitably controlled to prevent contamination of products (e.g. as a source of food poisoning or introduction of allergenic material to the site).
Interpretation
In some operations (e.g. sites manufacturing a product with an allergen claim), specific allergens present a particular risk. These sites should specify any relevant company policies to confectionery vending suppliers and catering facilities (e.g. a ‘no nut policy’ on the site due to the manufacture of ‘nut-free’ products).

BRC Standard 5.3 MANAGEMENT OF ALLERGENS
5.3.1 The site shall carry out an assessment of raw materials to establish the presence and likelihood of contamination by allergens
Interpretation Raw material assessment
Raw materials are a potential source of allergens and of cross-contamination. Therefore, the supplier approval and raw material risk assessment procedures (clause 3.5.1) must include an assessment of raw materials for the presence of allergens and the potential for cross-contamination.
Raw material specifications (including flavourings, additives, carriers and processing aids) must be agreed with each raw material supplier and include the allergen status (both content and risk of cross-contamination) of the materials.
 

BRC Standard 5.3 MANAGEMENT OF ALLERGENS
5.3.4 Documented procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination into products not containing the allergen. This shall include as appropriate:
• restrictions on food brought onto site by staff, visitors, contractors and for catering purposes.
Interpretation:
The allergens that may be handled in non-production areas of the site – for example in canteens or in new product development. A policy for food brought onto site by staf, or used in vending machines or catering facilities, should be developed. The policy may ban certain allergens or restrict them to certain areas of the site.

BRC Standard 7.4 PROTECTIVE CLOTHING
7.4.1Interpretation Documented protective clothing policy
The company is required to determine the procedures for application and use of protective clothing, based on a risk assessment. The risk assessment must consider foreign-body, microbiological and allergen risks as appropriate, as well as general good practice principles. It must document:
• procedures for canteens and smoking areas

So on to training, if you have decided there are no risks from raw materials there is general training to make staff aware of key allergens and any restrictions you applying in staff bringing them on site, where they are stored and where they are to be consumed. There is also the control of catering facilities, to consider so what allergens are being handled there and what controls you are going to apply such as the removal of protective clothing and hand  washing.

Your rules can be covered in induction training:
BRC standard 7.1 TRAINING
7.1.1 Interpretation Initial training and supervision
The following may be considered:
• induction training for all staff, covering company policies on hygiene, allergens, quality requirements, a basic introduction to HACCP etc.

Engineers may need to be also aware of allergens in maintenance chemicals and technical staff who are scrutinising raw materials more in depth training:

BRC standard 7.1 TRAINING
7.1.4 All relevant personnel, including engineers, agency-supplied staff and temporary staff and contractors, shall have received general allergen awareness training and be trained in the site’s allergen-handling procedures.
Interpretation Allergen training
All personnel (including all agency-supplied and temporary staff, and contractors) involved in handling ingredients, equipment, utensils, packaging and products must receive training to raise awareness of food allergens and the specific allergen measures used by the company.
The level of training should be appropriate to the individual’s role. For example, junior staff may require only a general understanding of the importance of allergens (information that could be included as part of the induction process), plus any specific procedures in which they are involved. However, the technical team will require greater detail.
Training records must be kept.

Kind regards,

Tony

Hi Tony,

I'm so impressed on how you site all example regarding allergen control/handling. I'm thinking to used this as controls for Handling allergen.

Because our last audit, the auditor almost raised us a non conformance regarding the subject. She said our controls are not clearly specified and very superficial.

Can you give me some link where i can find the whole interpretation of each BRC clause to make me understand more the standard.

I would really appreciate some help. (BTW, I was promoted  :happydance:  that's why I'm doing everything I can to not disappoint the management).

Thanks,

Joan

Hi Joan,

Thank you for your comments.

You can buy the BRC Interpretation Guideline here or you should have free access if you subscribe to BRC Participate

Kind regards,

Tony

We do not have any allergens in our raw materials.  But our employees eat meals, and so could be the source of allergen contamination if they were sloppy about making sure that no stray food from their meals made it back into the production areas on their clothing, hair, hands, etc.  So, training the employees about why it is important to use the PPE, wash hands, make sure clothing does not contaminate, should include information about allergies and allergen control.  I include a little spiel about what an allergy is, and how little it takes to trigger an allergic reaction so they know how important it is to be careful.

I've attached the slides that are put into the sanitation and personal hygiene training for allergen awareness training.

Allergens.pdf   298.58KB   898 downloads

Martha

We do not have any allergens in our raw materials.  But our employees eat meals, and so could be the source of allergen contamination if they were sloppy about making sure that no stray food from their meals made it back into the production areas on their clothing, hair, hands, etc.  So, training the employees about why it is important to use the PPE, wash hands, make sure clothing does not contaminate, should include information about allergies and allergen control.  I include a little spiel about what an allergy is, and how little it takes to trigger an allergic reaction so they know how important it is to be careful.

 

I've attached the slides that are put into the sanitation and personal hygiene training for allergen awareness training.

 

Allergens.pdf

 

Martha

Wow Martha, that's a really visual presentation. I love it.

In addition to specifica allergen training, do you have any more requirement? We usually recommend to our clients to ban eating some kind of products (e.g. nuts).

Just a note on this:

We recently had our Gluten Free certification and our auditor fixated on  hand washing detergent so we had to send our allergen control form to the supplier(same as the one we send to raw material, processing aid, lubricant suppliers).

No peanut or any other nut in the cafeteria is fine but banning gluten in the cafeteria would have been a bit too much control so we reinforced PPE (lab coats, aprons, hair/beard nets) not to be worn in the cafeteria, hand-washing for 20 seconds( Happy Birthday Song time). potential allergen cross contamination points are marked out on our HACCP flow diagram. Examples of our potential cross contamination points were, cafeteria to plant, office to plant, bathroom to plant, lockers to plant, warehouse to plant, maintenance workshop to plant. "Gluten free facility" refers to the processing and packaging area only

Btw this Friday Webinar from IFSQN also helped :giggle:

The slides are not very helpful on their own and should be read in conjunction with the webinar recording.

Webinar Recording: Best Practices in Allergen Management

Regards,

Simon

Lovely presentation Martha, am definitely going to "borrow" some of your ideas.  Would you be willing to share your sanitation and personal hygiene awareness training as well please?

Regards

Sharon 

Wow Martha, that's a really visual presentation. I love it.

 

In addition to specifica allergen training, do you have any more requirement? We usually recommend to our clients to ban eating some kind of products (e.g. nuts).

We do not limit what our employees eat, since the production equipment is totally enclosed and there is almost no exposure to the workers.

Martha

Lovely presentation Martha, am definitely going to "borrow" some of your ideas.  Would you be willing to share your sanitation and personal hygiene awareness training as well please?

 

Regards

 

Sharon 

Thank you, Sharon.  I took the hygiene and sanitation portion of the full training and removed references (and pictures) that relate to our products and production.  What is left is a more "generic" training on food borne illness, HACCP, sanitation and personal hygiene.  Hope it helps you.

We have some workers whose formal education has been limited.  I try to take the important information and put it into words to which everyone can relate.  There are always pictures, and sometimes a bit of humor.  The mental image of an astronaut having food illness in space always brings a smile.  If the trainee smiles or laughs at the right times, I know that they understand what I am saying.  If not, then I talk a little more about the critical information and do a more basic summary at the end.

Sanitation and Personal Hygiene Generic.pdf   687.42KB   414 downloads

Martha

Thanks so much Martha.  Your material is excellent, and I will definitely use some of your slides.  

We do not have any allergens in our raw materials.  But our employees eat meals, and so could be the source of allergen contamination if they were sloppy about making sure that no stray food from their meals made it back into the production areas on their clothing, hair, hands, etc.  So, training the employees about why it is important to use the PPE, wash hands, make sure clothing does not contaminate, should include information about allergies and allergen control.  I include a little spiel about what an allergy is, and how little it takes to trigger an allergic reaction so they know how important it is to be careful.

 

I've attached the slides that are put into the sanitation and personal hygiene training for allergen awareness training.

 

Allergens.pdf

 

Martha

Very nice presentation Martha

Bumping this thread to say thank you to Martha for the presentations.

Will be very useful for me when trying to put together a refresh course about importance of allergen awareness and hygiene!

Lovely I love all the presentations. They helped out my team. We are almost close to a Desk audit and we are getting alot of training done at our facility. Thank You