BRC v. 7 Section 5.3 Management of allergens
Hello Everyone :)
I have problem with BRC v. 7 Clause 5.3
My company is production rapeseed oil. This clause speak us that We should conduct analysis of raw materials to the presence of allergens.
In the production of rapeseed oil raw materials which we use are not allergenic. What Can i Do?
Greetings.
Patrico
Like you said, if you use materials without allergens, in analysis you can only write that raw materials (in your case - rapeseed) are not allergenic
If none of the materials used are allergenic your only concern should be the possibility of cross contamination in growing, harvesting or transporting the raw materials. You should document the assessment, what are the possible sources and the risk of cross contamination and how you can control them if the risk is there. I don't know anything about processing rapeseed oil but it is possible that any allergen present would be inactivated. After all soy is an allergen but soya oil is not.
Patrico, maybe the problem is in the translation of the standard. In English, it does not require "analysis" of the raw materials, but it requires "assessment" to establish the presence and likelihood of contamination by allergens. It has to include review of specs and getting information from suppliers, for example through questionnaires, to understand the allergen status of the raw material. This is in 5.3.1, and allows for you to determine that your raw material does not contain allergens, using just information that you can get from the supplier.
We use pulp sheets made from wood and bamboo in our products. There are no allergens in that. I have a documented risk assessment that shows how we know that there are no allergens present, and every year we have our pulp suppliers fill out a questionnaire that states that there are no allergens in their products. And I have researched and understand how their pulp sheets are manufactured., so I know that there are no allergens present.
As long as you document how you determine that there are no allergens there, you are OK.
Don't forget, that allergen management requires that you show how you protect your allergen-free raw materials from the allergens on site that your workers bring in their lunches. Part of your plan has to detail how you prevent contamination from crumbs from their meals.
Martha
We have a quality form in chart format which we send out to suppliers who do not have their own allergen chart. something like the attachment below.
Even if no raw material contains allergen, there remains the possibility of those raw materials being cross-contaminated with allergens. Hope this helps