Segregation of raw material in a small bakery

I am working with a client who had an audit (prior to me) and the auditor marked them down for their allergen management. The auditor told them they needed to have all incoming material labeled and segregated even things like wheat and soy. Every single one of their products contain wheat and soy. They do segregate the couple of allergens that pertain to only some of their products (nuts/dairy/egg) but they have the soy and wheat products co-mingled and sometimes due to space the wheat and soy are stored over the nuts/dairy/egg.

So basically since wheat and soy are in everything they treat them as if they are not allergens during storage. They have in their plans (SOP/HACCP) this outlined and stated that if that ever changed they would re-evaluate.

My big question is how to justify this. It makes sense (at least to me, please if I am incorrect point it out), but I need to be able to justify this for the auditor.

Thanks.

Hi elf,

Text is slightly confusing to me. I deduce that some ingredients contain both  wheat/soy (W/S) allergens. Other ingredients contain neither W or S but do contain various  other allergens.

The typical auditor reasoning is usually based on risk assessment, ie risk of allergenic cross-contamination in the defined area. The risk relates to storage location/accessability/handling etc

As i understand, in an ingredient storage scenario where some allergenic variation exists, it is auditorially expected to have differential allergen labelling for all items. i deduce from the OP this has not yet been done. Hence auditor's 1st comment.

Assuming labelling did exist, it seems reasonable to me to minimally expect all the W/S containing but different ingredients to be mutually "separated," simply as good practice. Co-mingling is an equally subjective term, ie how/how much ?

The specific operational expectations associated with "segregation" seem to occasionally vary between Standards/auditors (I am not a SQF user) so what did your auditor actually require for  "segregation" of allergenically identical products.?

So from a common sense, let's not reinvent the wheel perspective, can you not validate the process but including a review of all labels where you can prove that each label/package lists both wheat and soy and zero products contain one or the other but not both, I would think that should appease an auditor

So from a common sense, let's not reinvent the wheel perspective, can you not validate the process but including a review of all labels where you can prove that each label/package lists both wheat and soy and zero products contain one or the other but not both, I would think that should appease an auditor

Hi scampi,

Bit of a brain teaser. i think it's wrong (not matched to the OP) but not 100% sure. :smile:

Scampi,

that is basically my solution just didnt know if there was anything solid to back it up. since every final product has wheat and soy then wheat and soy should be able to be treated as 'non'allergen. so I could store the nuts on the ground level and wheat/soy above because the  nut item will be in a wheat/soy product. but I would still not store nuts above a wheat/soy because not all wheat/soy has nuts.

I just wanted a solid validation to the method.

Hi Q.elf,

CFIA may address yr“co-mingling question somewhere but unfortunately I cannot find any mention.

However I have located some support for a “combined” procedure from the well-known FARRP (see below). Whether a FARRP recommendation would be an acceptable validation for  yr auditor I cannot say.

(1-3) are Canadian quotes, (4) is ex-FARRP

(1)

incoming materials and packaging materials are handled and stored in a manner that prevents damage and/or contamination (including cross-contamination with allergens).

Incoming materials containing allergens are clearly identified (using a color code or other identification system).

http://www.inspectio...4870197?chap=10

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(2)

Storage and Handling: Store and handle allergenic foods and ingredients in a manner that will avoid cross-contamination with other food products. This may require dedicated storage areas for the various allergen-containing ingredients handled in the plant. If it is not possible to store allergenic foods and ingredients in separate areas, it is suggested they be stored below non-allergenic foods and ingredients, e.g., in bottom shelf/rack, to prevent allergens falling on other foods and ingredients. Ensure that allergenic foods and ingredients are clearly identified by signs or colour codes.

>>>>> 

Incoming Ingredients: Obtain accurate ingredient information from all suppliers to identify all allergens, including allergens present as components (ingredients of ingredients). This can be done by obtaining ingredient specification sheets, letter of guarantees, certificate of analysis or a complete list of ingredients. Ensure that they meet your company's specifications and are completely labelled. You may also consider adjusting formulations to avoid allergenic ingredients.

http://active.inspec...introe.aspx?i=6

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(3)

Store allergenic food ingredients separately from other ingredients – at least 1.5 metres should be maintained between allergens and other  ingredients if it’s not possible to store them separately.

Store allergenic ingredients on the bottom of racks to avoid accidental spills on items below them.

Identify ingredients with an “allergen” and/or a colour-coded tag.

food allergens as chemical hazards.pdf   381.48KB   69 downloads

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(4)

Storage

Store allergenic ingredients or products separately to prevent cross-contact. Protocols may include:

- Using clean and closed containers

- Designating separate storage areas for allergenic and non-allergenic ingredients and/or products.  When segregated storage is not possible, use other methods such as not storing allergens over non-allergens, storing like allergens (milk and whey) together, etc.

- Using and documenting clean up procedures for spills or damaged containers of allergens

- Using dedicated pallets and bins

- Using clearly designated staging areas for allergenic foods and ingredients

FARRP - Allergen Control Plan.pdf   210.07KB   81 downloads

(see Pg 5/15)

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Hopefully of some help.