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Do we need to treat barley gluten as allergen in the factory?

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#1 Ewelina.M

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Posted 22 June 2016 - 06:36 AM

Hello all,

 

I work in the factory where all produced product contain wheat gluten( pastry products) , therefore we have no controls around this allergen on site . In addition some of our products contain barley gluten in the filling.

 

My question is: Do we need to treat barley gluten as allergen in the factory?

 

Thank you for any help.

 

 



#2 Irishlass105

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Posted 22 June 2016 - 09:25 AM

Yes!

 

I worked in a factory which breaded poultry product and we had gluten in everything therefore we didnt class it as an allergen. Everything else we did ie infills such as garlic, cheese and ham, mushroom and peppered sauce. If it is a seperate product and contains barely and barely is a allergen it would be classed as such. 



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#3 GMO

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Posted 22 June 2016 - 12:06 PM

Really interesting question.  The allergen is not stated in legislation as "Gluten" it is "cereals containing gluten" which includes wheat and barley.

 

1. Cereals containing gluten (eg wheat (such as spelt and khorasan wheat), rye, barley, oats, or their hybridised strains), except:
(a) wheat-based glucose syrups including dextrose
(b) wheat-based maltodextrins
© glucose syrups based on barley
(d) cereals used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages.

 

As they are listed under the same subset, in this case, I would not control them differently, I think, however, I would ask advice from the retailer if they are a retailer brand.

 

Why do I say "I think"?  Well I have first hand experience nowadays with allergens as I have two close friends with allergies and my son.  One of my friends is allergic to wheat and, now, he thinks other items containing gluten.  Initially his diagnosis was only for wheat though which is making me wonder two things; do factories control the two together and that's why he's reacted to barley products?  Or is everyone who has an allergy to wheat also allergic to barley?

 

The other reason why I'm a little unsure is that I know from first hand experience how allergies can be treated as one block which annoys the hell out of me.  My son is allergic to two specific tree nuts for example and not others and not peanuts.  So if a factory control peanuts using the same scoop as they'd use for one of the treenuts he has an allergy to, then he may have a reaction.  Likewise if they use the same scoop for hazelnuts which he's not allergic to and one of the ones he is, that could be an issue and they are all in the same category of the legislation.

 

8. Nuts, i.e. almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoiesis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia nuts and Queensland nuts (Macadamia ternifolia), except:
nuts used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages.

 

But allergic consumers would avoid all nuts right?  Wrong.  In fact, the current medical advice my son has been given is to actively eat the nuts he's not allergic to in order to make sure an allergy doesn't develop.

 

I appreciate nuts and gluten containing cereals are not the same thing in terms of likely reaction, however, anaphylaxis to wheat and gluten containing cereals can occur as has happened with my friend.  I suppose the difficulty is every test will test for gluten. 

 

Some specialist advice is needed I think?  Ultimately I might be getting into a twist because the allergenic compounds in both wheat and barley are identical but better to get something official to confirm it because, as I've found, allergic response between nuts is definitely not identical so I wouldn't assume.



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#4 Charles.C

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Posted 23 June 2016 - 05:09 AM

Hello all,

 

I work in the factory where all produced product contain wheat gluten( pastry products) , therefore we have no controls around this allergen on site . In addition some of our products contain barley gluten in the filling.

 

My question is: Do we need to treat barley gluten as allergen in the factory?

 

Thank you for any help.

 

Hi Ewelina,

 

Allergenic queries can get complicated. The difficulties are often due to a mixture of factors relating to, for example, scientific terminologies/interpretations, limited allergenic knowledge, labelling legalities.

 

As per previous post (EC quote ?)  the labelling requirements for  “food allergen” may dictate the haccp approach, eg where control must  be applied and how for  (allergenic)  contamination /  intrinsic hazards. UK allowances (if any) regarding “advisory”  labelling might also be involved but are not intended to promote avoidance of cleaning procedures.

 

A fair amount of background wheat/barley/gluten allergenic knowledge in this, Canadian oriented, wheat/barley thread portion starting (post 11) here –

 

http://www.ifsqn.com...ens/#entry75046

 

Another analogous query (wheat /oats) re-starts at Post 19 and shortly petered out due lack of Poster knowledge.


Kind Regards,

 

Charles.C


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#5 Ewelina.M

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Posted 23 June 2016 - 06:29 AM

Thank you for all your replys.

 

Just to add to my post I can says, that barley gluten is declared on our packaging for products containing that ingredient. What I'm after more is: do we need to keep any controls in place when changing over from product containing barley gluten to product without barley gluten (all products contain wheat gluten). Amounts of Barley in the products are very small as barley is the component of our ingredients.

We introduced a water rinse between barley and non-barley cooks but in some instances we are not able to validate the effectiveness of cleaning. Some of the cooks contain wheat as well. There is no test for barley on the market and we can only test product for gluten. Which will also pick up wheat gluten.

We have never controlled barley before and I have doubts that it is necessary now.  Very difficult to find any clear info about it.



#6 Charles.C

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Posted 23 June 2016 - 10:03 AM

Hi Ewelina,

 

Like yourself, I don't know the answer. It's tempting to say "never mind" but please refer again to the caveats in Post 3 regarding potencies.

 

The "Precautionary Principle" would probably recommend to assume  a worst-case scenario until you have information to the contrary.

 

If you study the link in my previous post, you will see for 2nd case (oats) a near-equivalent admission

 

I deduce from the literature that some allergenic proteins in wheat and barley may be "analogs" but this is not a consistent feature.

 

http://www.eatingwit...eatallergy.html

http://www.mayoclini...es/con-20031834

 

Additionally various of the wheat allergens cross-react with those of barley which presumably hinders the development of  methods to differentiate them in a food.

 

 

I also could not find any testkit claimed to differentiate between wheat and barley from an allergenic POV.


Kind Regards,

 

Charles.C


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#7 RMAV

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Posted 23 June 2016 - 12:57 PM

In the U.S., there is provision for the unintended cross-contact or unavoidable presence of gluten (in the gluten free standard) up to 20ppm. Is there such a provision in the markets to which you're sending your product?



#8 GMO

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Posted 27 June 2016 - 03:17 PM

It might sound daft but is it worth talking to a medical allergy specialist?  You see some grains are labelled as containing gluten but, if pure, don't.  For example, now I think this is right, oats do not contain gluten but they are grown in fields where there might be a wheat field next door or may have left over seeds from a previous sowing, then the same equipment, storage and transport is used so widespread contamination of oats is really common.  With barley though I'm not sure if the gluten is within the barley or a massive cross contamination issue like you have with oats.  I would say though an immunologist is more likely to know the answer to that than a food safety specialist.  That said, RSSL are a pretty good company on advising on allergies.  I went along to one of their "allergy in a nutshell" briefings which was excellent but seem not to be happening anymore.  One of the speakers said they were aware of research ongoing on allergies and the "likely" reaction.  In fact they were suggesting that reactions to some were generally much worse than anticipated whereas others were questionable if they should still be on the list.  If you google them, they might be able to advise.

 

You could go down the route of using wipes or a full clean between products containing barley and products not.  (The best way of course would still be to schedule the non barley before the barley then it's not an issue.)  But what we're struggling with here is simply "is barley a different allergen to wheat?" which isn't 100% clear to me.  If it is, then that validated clean is needed.  Although ELISA is preferred for allergen tests, it's worth checking (if it is a different allergen) if a PCR method is available.  I had to use PCR when I was using anchovy in a product.  The only ELISA tests available were for white fish and so would have given me lovely negative results.  

 

Of course some unscrupulous manufacturers would just slap on "may contain traces of barley" and be done with it but I think this is a question worth answering well as that water clean may be a complete waste of time, if you confirm that, you will be a God amongst Technical people in Operations eyes!  If you confirm it is different, they may not be quite so happy but at least you've protected your consumers to the best of your ability.

 

Good luck and come back to tell us how you get on, I'm curious and I like to learn!   :smarty:



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#9 Charles.C

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Posted 27 June 2016 - 03:33 PM

Hi GMO,

 

As i read it, the allergenicity is linked to a variety of proteins. This is ongoing research afaik.

 

Those so far identified in barley and in wheat are sometimes different, sometimes homologs (eg links' inferences in Post 6).

 

Presumably a different, but analogous, scenario exists for tree nuts as previously mentioned. I wonder how this is (officially) handled.


Kind Regards,

 

Charles.C


#10 GMO

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Posted 27 June 2016 - 03:55 PM

Hi GMO,

 

As i read it, the allergenicity is linked to a variety of proteins. This is ongoing research afaik.

 

Those so far identified in barley and in wheat are sometimes different, sometimes homologs (eg links' inferences in Post 6).

 

Presumably a different, but analogous, scenario exists for tree nuts as previously mentioned. I wonder how this is (officially) handled.

 

I suppose in terms of legislation, you would probably be duly diligent in treating them as one allergen but if it's "right"...?



#11 Charles.C

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Posted 27 June 2016 - 04:11 PM

Hi GMO,

 

At least in the case of USA, tree nuts seem to be handled as separate allergens/hazards, eg  -

 

For example, even though they may be handled in the same facility, packaged cashews must not have traces of walnuts in them.

 

Attached File  Industry_Handbook_for_Safe_Processing_of_Nuts.pdf   1.52MB   13 downloads

 


Kind Regards,

 

Charles.C


#12 ShannieB89

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Posted 27 June 2016 - 04:25 PM

Thank you for all your replys.

 

Just to add to my post I can says, that barley gluten is declared on our packaging for products containing that ingredient. What I'm after more is: do we need to keep any controls in place when changing over from product containing barley gluten to product without barley gluten (all products contain wheat gluten). Amounts of Barley in the products are very small as barley is the component of our ingredients.

We introduced a water rinse between barley and non-barley cooks but in some instances we are not able to validate the effectiveness of cleaning. Some of the cooks contain wheat as well. There is no test for barley on the market and we can only test product for gluten. Which will also pick up wheat gluten.

We have never controlled barley before and I have doubts that it is necessary now.  Very difficult to find any clear info about it.

Hi Ewelina,

 

I can understand your dilemma as I have had different experiences with inspectors and auditors concerning allergen management. Firstly, declaration of packaging communicates to customer that you have identified that barley is present, but that is not sufficient especially when dealing with something that can cause adverse health effects and worst death.. Secondly: Controls are required during change over from barley to non-barley products since you have identified as well as base on regulations that barley is indeed an allergen. While the amount is deemed to be small, that cannot justify reasons as to not to control it because again, it is an allergen and may lead to very serious repercussions, to either a customer or to your business. 

I am a novice on this so all that I am writing is related to brief readings done as well as auditor reports and such.

 

 

When testing the effectiveness of cleaning (and someone correct me if I am wrong), my company doesn't test for a specific protein (gluten), we test for the evidence of residue. We conclude that once there is no presence of residue (physical or chemical or biological) then there is no allergen on the equipment. (Could someone tell me if this rational is acceptable?)

 

Not sure if the water rinse sounds feasible or effective as a cleaning method to eliminate barley present. What is required for food safety system however is VERIFICATION and VALIDATION, these are a must! Verification of cleaning effectiveness maybe swabbing after the barley production run and validation may be having an accredited external lab validate your swabs say bi-annually or annually.

 

At the end of the day, once an allergen is identified in your facility you must have control measures in place for it. The reason it may seem difficult now to do so is because wheat, which is used in everything was never considered to need measures in place however with the introduction of barley, things have now become more strict I guess.

 

Best of the best with this, I myself will be following this post as I need guidance as well.

 

 

Best Regards,

Niesha



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#13 Charles.C

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Posted 27 June 2016 - 04:37 PM

Hi Niesha,
 

 

When testing the effectiveness of cleaning (and someone correct me if I am wrong), my company doesn't test for a specific protein (gluten), we test for the evidence of residue. We conclude that once there is no presence of residue (physical or chemical or biological) then there is no allergen on the equipment. (Could someone tell me if this rational is acceptable?)

 

Cleaning and Allergen are 2 different things.

 

 For allergens, It probably depends on yr local Regulatory rules or relevant Food Standard (if any), eg -

 

http://www.foodsafet...clean-standard/


Kind Regards,

 

Charles.C


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#14 ShannieB89

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Posted 28 June 2016 - 12:58 PM

Hi Niesha,
 

 

Cleaning and Allergen are 2 different things.

 

 For allergens, It probably depends on yr local Regulatory rules or relevant Food Standard (if any), eg -

 

http://www.foodsafet...clean-standard/

 

Thank you very much for the link



#15 GMO

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Posted 29 June 2016 - 07:34 AM

 

When testing the effectiveness of cleaning (and someone correct me if I am wrong), my company doesn't test for a specific protein (gluten), we test for the evidence of residue. We conclude that once there is no presence of residue (physical or chemical or biological) then there is no allergen on the equipment. (Could someone tell me if this rational is acceptable?)

 

 

 

It can be effective to say the clean is an effective removal of your allergen residues IF you have validated that your standard of visual clean does mean lack of allergen presence.  So you need to have done some work to prove that your normal cleaning procedures can, in a reproducible way, remove detectable allergens. 






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