9 replies to this topic

[DNFKEV]

We are a tree nut processing facility and currently having trouble figuring out how to manage allergens. Tree nuts are a major food allergen and all of our products contain tree nuts. Some products contain dried fruit as well. Some ways we try managing them is having separate utensils and mixing bowls for tree nuts and dried fruits but they still are processed into a single package. Tree nuts and dried fruit are also stored in segregated areas and they can never be stored together. We're currently working on an unintentional allergen policy from entering the facility. I've also read the Handbook for Safe Nut Processing but I'm still confused. So my questions are:
 

Because all our ingredients are tree nuts, do we treat them as one single allergen, or do we have to treat each ingredient as its own allergen profile?
 

Also, since we process tree nuts, do we have to have a stringent allergen management program?

 

Any advice and clarification would be great because SQF 2.8.1 is driving me nuts.

 

Thank you

[Scampi]

Lol, i like the pun you made there

 

Are tree nuts in ALL your finished products without exception?

[DNFKEV]

Yes, all our products contain tree nuts. Some products will be dried fruit/tree nut mix, or some will be a complete mix of tree nuts. 

 

and thanks lol

[Scampi]

If all products contain ALL the tree nuts you use (almonds,cashews etc) then you don't really have an allergen cross contamination issue to deal with and i would state that in the allergen management plan as such with reference to your product specs and no, I think you could treat them all as one single allergen (providing peanuts are NOT included in your tree nut list)

 

Your allergen mangement program needs to explain how you prevent unintentional cross contamination with allergens you do not use, reference back to your approved suppliers (pest control materials as well) and how you ensure things like soy, milk etc do not make it into your facility.

[gmurray327]

When I took the Preventive Controls for Human Food, they mentioned that all nuts could not be stored together.  It's more than just allergens, there are other biological hazards such as listeria and ecoli that must be addressed.  Different tree nuts have different risks for contamination.  I wish I'd ask more about that now...

[DNFKEV]

If all products contain ALL the tree nuts you use (almonds,cashews etc) then you don't really have an allergen cross contamination issue to deal with and i would state that in the allergen management plan as such with reference to your product specs and no, I think you could treat them all as one single allergen (providing peanuts are NOT included in your tree nut list)

 

Your allergen mangement program needs to explain how you prevent unintentional cross contamination with allergens you do not use, reference back to your approved suppliers (pest control materials as well) and how you ensure things like soy, milk etc do not make it into your facility.

 

So having a machine process walnuts, then changeover to cashews wouldn't be a problem?
(We do have allergen warning labels)

 

gmurray327 - We also receive a COA from suppliers to ensure that raw materials received pass regulatory standards. So do you think it'd still be good to just keep them segregated as part of an allergen control method?

[Scampi]

you don't want to store raw material mixed together for lots of reasons (recall of just walnuts, but you went ahead and premixed almonds walnuts and pistachios, now you have to destroy all of them)  so segregation is not just for allergen control

 

I am not an allergen specialist, but please read this link

https://www.foodalle...ergens/tree-nut

 

 

Ensure that your labeling matches the country of sale requirements for allergen labeling and you should be good

 

What specifically do you labels say? "contains walnuts and manufactured in a facility that uses other tree nuts" as an example

[DNFKEV]

Gotcha

 

Our labels only state "Contains tree nuts". From reading what you said, it seems that it may not be sufficient enough. So if it stated "contains walnuts and manufactured in a facility that uses other tree nuts", it would be sufficient enough to not worry about cross-contamination in that aspect? We do sanitizing procedures to ensure that biological hazards are removed for processing.

[smgendel]

The answer to this can be a bit complex, and depends on where you are.  I can answer for production in the US.  The controls needed depend on whether all of your products have all the same tree nuts.  If that is the case, you don't have any cross-contact issues in the facility but do need to be sure that your labels are correct. If different products have different tree nuts (or mixes of tree nuts) then you need to handle each species individually and prevent cross-contact between them.

 

You do need to consider the potential for cross-contact or mislabeling by your suppliers. That could require a supply chain applied control. 

 

For products sold in the US, the ingredient list or contains statement MUST list each individual type of tree nut.  Any advisory statement (such as "may contain") is a separate statement and should not be part of the legally required contains statement. 

[DNFKEV]

Thank you all for the very helpful insight.