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#1 Inverse

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Posted 12 July 2016 - 07:57 AM

Hi all,

 

I am really confused about allergen control in the premises, so I thought you might be able to help me? We will have an audit soon, so any help will be much appreciated!

 

Summary: 

Our whole site is nut-free, so no nuts (etc) are allowed. No other allergens are handled on the factory floor. We produce single-ingredient product.

Our factory is downstairs, canteen and offices are upstairs. Employees sometimes have allergens (except nuts) either in the canteen or in the offices. Is it allowed? It doesn't reach factory floor- we undergo all changing procedures, so I would guess it's fine?

We just developed new product which contains sesame seeds. It is blended and packed elsewhere but we keep some stock of it upstairs in the office. Is it allowed? Do we treat it as any other food product (allergen) that is brought on site? I am quite worried because sesame seeds are tiny and it's more difficult to control them. However, they are sealed and in closed boxes. 

 

Thank you in advance!

 

 



#2 ads78

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Posted 12 July 2016 - 08:13 AM

Sealed sesame In closed boxes shouldn't be a problem, as long as you are not opening them on site. You will need an allergen spillage procedure. And consider if the office is the best place to store food..

 

Allergens in the canteen are ok providing its not Nuts, and you have trained people on hand washing and basic allergen awareness.

 

I would recommend that you cover the risk of allergen contamination either through your HACCP plan or a separate allergen risk assessment where you can outline the risk and how you will control it.



#3 Inverse

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Posted 12 July 2016 - 09:03 AM

Sealed sesame In closed boxes shouldn't be a problem, as long as you are not opening them on site. You will need an allergen spillage procedure. And consider if the office is the best place to store food..

 

Allergens in the canteen are ok providing its not Nuts, and you have trained people on hand washing and basic allergen awareness.

 

I would recommend that you cover the risk of allergen contamination either through your HACCP plan or a separate allergen risk assessment where you can outline the risk and how you will control it.

Thank you!

 

Do you mean that we can't open our new product (which contains sesame seed) in the canteen or offices? I know that it's not the best place to store food but currently we don't have any other option..



#4 ads78

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Posted 12 July 2016 - 09:22 AM

You would need to give a little more detail.

 

Presumably if its made off site, packed and sealed, you don't need to open it? Or is it a component of another product you are making? If it is a factored good i.e. it comes in boxed and sealed and you sell it straight on, you would just need to risk assess the likelihood of spillage within the premises and come up with mitigation in my opinion. This would normally be covered in your HACCP prerequisites under allergen controls, supplier approval, and sometimes by a further allergen risk assessment (which may be too far in your case). If you need to open it on site, that's a separate issue, that will need some kind of risk assessment.

 

Needless to say, not knowing your process and requirements makes things a little more difficult, but these are the broad strokes!



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#5 Charles.C

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Posted 12 July 2016 - 12:43 PM

BRC ??


Kind Regards,

 

Charles.C


#6 QAGB

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Posted 12 July 2016 - 01:37 PM

Hi all,

 

I am really confused about allergen control in the premises, so I thought you might be able to help me? We will have an audit soon, so any help will be much appreciated!

 

Summary: 

Our whole site is nut-free, so no nuts (etc) are allowed. No other allergens are handled on the factory floor. We produce single-ingredient product.

Our factory is downstairs, canteen and offices are upstairs. Employees sometimes have allergens (except nuts) either in the canteen or in the offices. Is it allowed? It doesn't reach factory floor- we undergo all changing procedures, so I would guess it's fine?

We just developed new product which contains sesame seeds. It is blended and packed elsewhere but we keep some stock of it upstairs in the office. Is it allowed? Do we treat it as any other food product (allergen) that is brought on site? I am quite worried because sesame seeds are tiny and it's more difficult to control them. However, they are sealed and in closed boxes. 

 

Thank you in advance!

 

 

Hi Inverse,

 

I second Ads78's response. It is definitely best not to allow nuts in your facility (in breakrooms and so forth) especially considering you don't handle allergens normally. You should also be cautious about other allergens as well; besides just nuts. Sometimes those things are harder to control, when people bring in their own food. In that instance, you would definitely want to install a handwashing station either inside the breakroom, or right outside of it before entering production. It would also be a very good idea to have people who handle product and primary packaging to wear gloves as well (if they don't already do that).

 

You definitely want to risk assess your breakrooms and non-production areas for allergens. You should also make flow maps to show flow of traffic to and from those areas. This will help you determine if you have any points of possible contamination and if traffic should be routed elsewhere to prevent it.

 

As for the sesame seeds, yes, you would treat them as any other allergen you have onsite. This is better if they stay sealed the entire time. Apparently they are being stored in an office? If that is the case, you still should make sure that they are stored in a manner so as to prevent contamination from occurring (for instance, storing the non-allergens above the allergens). If you must work with the product with sesame seeds, wear gloves and other PPE in the office, clean up the area after handling, and wash your hands and arms if you have to go elsewhere. You should make sure your receiving department checks the incoming pallets before they come off the van trailer to make sure there aren't any broken bags or boxes though. Even so, as Ads78 stated, you should have an allergen spillage procedure in the event the product is damaged somehow. You should also include the flow of receiving and storing product containing sesame seeds in your flow map.

 

QAGB



#7 Inverse

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Posted 12 July 2016 - 01:37 PM

You would need to give a little more detail.

 

Presumably if its made off site, packed and sealed, you don't need to open it? Or is it a component of another product you are making? If it is a factored good i.e. it comes in boxed and sealed and you sell it straight on, you would just need to risk assess the likelihood of spillage within the premises and come up with mitigation in my opinion. This would normally be covered in your HACCP prerequisites under allergen controls, supplier approval, and sometimes by a further allergen risk assessment (which may be too far in your case). If you need to open it on site, that's a separate issue, that will need some kind of risk assessment.

 

Needless to say, not knowing your process and requirements makes things a little more difficult, but these are the broad strokes!

 

You're right, we don't need to open it but some employees are confused why they can't consume this product in the canteen (because of sesame seeds) but can have any other allergens (such as milk) and I'm not entirely sure what I should tell them (except for the fact that sesame seeds are more difficult to control due to their size)..

This product is not a component of another product and it doesn't even reach our factory door, so I only have a risk assessment for possible spillage before despatch. I hope that's enough.

 

Thanks again! 



#8 Inverse

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Posted 12 July 2016 - 01:42 PM

Hi Inverse,

 

I second Ads78's response. It is definitely best not to allow nuts in your facility (in breakrooms and so forth) especially considering you don't handle allergens normally. You should also be cautious about other allergens as well; besides just nuts. Sometimes those things are harder to control, when people bring in their own food. In that instance, you would definitely want to install a handwashing station either inside the breakroom, or right outside of it before entering production. It would also be a very good idea to have people who handle product and primary packaging to wear gloves as well (if they don't already do that).

 

You definitely want to risk assess your breakrooms and non-production areas for allergens. You should also make flow maps to show flow of traffic to and from those areas. This will help you determine if you have any points of possible contamination and if traffic should be routed elsewhere to prevent it.

 

As for the sesame seeds, yes, you would treat them as any other allergen you have onsite. This is better if they stay sealed the entire time. Apparently they are being stored in an office? If that is the case, you still should make sure that they are stored in a manner so as to prevent contamination from occurring (for instance, storing the non-allergens above the allergens). If you must work with the product with sesame seeds, wear gloves and other PPE in the office, clean up the area after handling, and wash your hands and arms if you have to go elsewhere. You should make sure your receiving department checks the incoming pallets before they come off the van trailer to make sure there aren't any broken bags or boxes though. Even so, as Ads78 stated, you should have an allergen spillage procedure in the event the product is damaged somehow. You should also include the flow of receiving and storing product containing sesame seeds in your flow map.

 

QAGB

 

Thank you very much for such an informative answer! Allergen control is a real challenge for me!



#9 Charles.C

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Posted 12 July 2016 - 02:37 PM

I suppose it just might also relate to the Product / Process.


Kind Regards,

 

Charles.C


#10 OG Bean

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Posted 18 July 2016 - 08:23 PM

Does anyone cover what employees can and/or cannot bring (allergen wise) into the plant in their lunches in a Allergen Control policy?

 

Just trying to decide if this is something I need to tackle.

 

Thoughts.  Any would help.



#11 Charles.C

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Posted 19 July 2016 - 02:52 AM

Does anyone cover what employees can and/or cannot bring (allergen wise) into the plant in their lunches in a Allergen Control policy?

 

Just trying to decide if this is something I need to tackle.

 

Thoughts.  Any would help.

 

Hi jcoomes,

 

It depends how much risk exists and perhaps how much you are prepared to take ?

 

eg see Post 6


Kind Regards,

 

Charles.C


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#12 Nidhi Arora Khare

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Posted 19 July 2016 - 09:26 AM

Does anyone cover what employees can and/or cannot bring (allergen wise) into the plant in their lunches in a Allergen Control policy?

 

Just trying to decide if this is something I need to tackle.

 

Thoughts.  Any would help.

Hi jcoomes,

 

As you have said earlier, your plant have an inbuilt canteen, so irrespective what an employee brings for his/her lunch allergens are still present at the facility.

 

I assume, your major concern being allergen control in the premises is to ensure the end product produced at your plant which as per specification do not carry any allergen shall not get contaminated through any other source of allergens. Correct.

 

Any product (apart from the ingredients used to produce the final product) is seen as a contamination to the product. I am sure your HACCP plan analysis is based on Physical/ Chemical/ Biological contamination identification for product ingredients and manufacturing process shall be able to identify the critical areas. These identified sections shall carry control procedures i.e.PRPs or CCPs

This shall also include a chance of physical contamination of any allergens via canteen or office area in case of mishandling, spillages or via personnel.

In that case you would need to document the allergens available at your site and the method to avoid cross contamination of the product produced at the site.

I hope this helps.

Rgds,

Nidhi



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#13 Charles.C

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Posted 19 July 2016 - 01:06 PM

Hi jcoomes,

 

IMO there are two key hazardous terminologies to think about -

 

(1) cross-contamination

(2) risk assessment

 

The relevance depends on yr product / process / HAZARDS.

 

Advisory Labelling offers a partial "Get-out" but, afaik, at least in USA, does not excuse (for FDA)  the processor from responsibility for implementing steps for PROCESS minimising (1).

 

How far the "process" mandatorily extends, for example to canteen/worker snack control i am unaware.


Kind Regards,

 

Charles.C


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