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Allergen Assessment---lockers lunchroom SQF 2.8.1.1

what??? allergens

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#1 Scampi

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Posted 03 April 2018 - 03:58 PM

Can someone please enlighten me on 2.8.1.1---an assessment of of workplace related food allergens from locker rooms, vending machines, lunchrooms, visitors."

 

 

What kind of cryptic requirement is this.............

 

Do you have or could you have allergens in the lunchroom------yep it's lunch

do employees wash hands prior to returning to work-----yep its a gmp requirement

 

 

 

ugh I'm not a fan of SQF, give me CFIA poultry anyday........at least the rules are straightforward!


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#2 FurFarmandFork

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Posted 03 April 2018 - 04:27 PM

My allergen program just recognizes the lunchroom as a potential source of cross-contamination, and outlines the controls used to prevent that from becoming an issue (no PPE in lunchroom, wash hands on returning to work, no food in plant). Your allergen plan just needs to make sure it notes that the lunchroom poses a hazard and that you've thought of it.


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#3 Plastic Ducky

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Posted 04 April 2018 - 01:52 PM

Hello Scampi,

 

Wow, you read my mind. I have been wondering about this exact requirement. When you compare 7.2 to v8 it is obviously new language they have put into the standard. I hope many more contribute to this thread because I would appreciate as many expert opinions as possible.  For starters, i will share that my perspective is coming from a packaging facility, or you could say a "facility claiming zero allergens and therefore a very simple allergen control program". As I had mentioned previously in the forum, we have all witnessed the auditor go and look in the vending machine for candies and food with peanuts..  But why? we had plainly stated in our employee GMP document as well as signage in the break-room, that "no food can leave" the break-room and hands must be washed upon exit. But still, every audit the auditor looks in the machine. I always wondered "why does he just look in the vending machine and not ask about employee lunches?". I mean, if he/she is so interested in peanuts in the vending machine, then what would stop and employee from bringing a five pound jar of peanut butter to work and selling peanut butter sandwiches to everyone? In the face of GMP and proper signage, is the vending machine inspection done because of the nature of the peanut allergen? We see food products that must claim if they were made in a facility that has peanuts.

 

I guess what I am getting at is this, I interpreted this addition to SQF v8 as meaning as the following;

 

 2.8.1.1---an assessment of of workplace related food allergens from locker rooms, vending machines, lunchrooms, visitors

 

1) is it possible a visitor/contractor could bring in an unapproved chemical? A chemical that is not on the "Chemical Registry"? Yes, it is possible and so we have added language to our visitor/contractor GMP document stating "no outside/unapproved chemicals". Likewise, employees are educated with the chemical control policy. 

 

2) is it possible a visitor/contractor could bring in an allergen? Is this the importance of the 2.8.1.1? A request to add language to the visitor/contractor GMP sign-off document specifically stating "NO peanuts/tree nuts"? Is it a request to extend the control beyond the vending machine and put language into the employee GMP document exclusively forbidding peanuts? If you claim to be a facility that is totally free of said allergens, maybe that is exactly what they are asking for..

 

I have been thinking about this for months, and I look forward to the opinion of other professionals here at IFSQN. 



#4 Scampi

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Posted 04 April 2018 - 02:06 PM

EXCEPT, we don't claim to be free of allergens.............we use a known allergen in half our Sku's........so shouldn't that be the focus as not people's lunches????  What, do say on the days we use mustard seed you may put mustard on your sandwich....the other days no.....

 

I agree, if I were a bakery who produced LABELED products that have a "made in a peanut free facility" then YES Absolutely there should not be any peanuts or peanut protein within the establishment, period. Would I change my visitor policy for that facility---YES, i would probably request that visitors remain peanut free the day of the visit---as there is a RISK 

 

Yes, looking forward to others input on this item


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#5 Plastic Ducky

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Posted 04 April 2018 - 02:08 PM

Scampi my friend,

 

I believe you and I are thinking very much alike..



#6 Scampi

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Posted 04 April 2018 - 02:11 PM

couldn't agree more

 

The more in depth I get with SQF the more I have come to realize that the retailers (yes that's whose shoulders I put the responsibility on) that have created this "scheme" (and it's it funny that that is the word everyone uses) have no idea about food safety and they really don't understand risk or even how a well developed HACCP plan functions

 

GRRRRRR


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#7 idealdreams

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Posted 05 April 2018 - 08:28 PM

I was overthinking this for quite a while just as you were, OP. The way we addressed it in our allergen management program was to show that we recognize the risk that our employees can introduce uncontrolled allergens into a zone 4 environment but we mitigate this by ensuring outside food remains only in the lunch room, employees must wash hands thoroughly after eating, employees may not wear their gloves, etc., etc. Pretty much just maintain good GMPs.



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