Allergen labelling of pre-packaged finished goods?
Hello IFSQN,
We are a storage and distribution 3rd party warehouse . All of our products are prepacked finished goods (case in/case out - cross dock). We are working towards acheving an AIB certification.
The nutrition facts printed on the individual items already have an "allergen warning" (E.G "this product may containe peanuts", fish etc etc).
Would it be necessary for our warehouse to add an allergen warning label on the shrink wrapped pallets we have in inventory or would the nutrition facts on the items be sufficient to be in compliance? Any ideas?
Exceprt from AIB consolditated standards for storage and distribution below:
5.11 Allergen Control Program The Allergen Control Program controls known allergens throughout the production process from receiving to distribution. Critical Requirements 5.11.1.1 The facility has a written Allergen Control Program that addresses allergens speci fi c to country regulations. 5.11.1.2 Procedures address: • Identification and segregation of allergens during storage and handling • Prevention of cross contact or contamination during processing by using measures such as: ◊ Production run scheduling ◊ Control of rework ◊ Dedicated production lines ◊ Comprehensive changeover procedures ◊ Equipment and utensils management • Product label reviews and control • Personnel awareness training and education • Verification of cleaning procedures for food contact equipment • Approved Supplier Program for ingredients and labels 5.11.1.3 The Program is updated when there are changes in: • Ingredients • Processing aids • Ingredient suppliers • Products • Processes • Labeling
The allergen labeling requirements on the products are for consumers. When handling in the warehouse it is good practice to identify pallets that have allergen-containing products. This makes it possible for you to segregate and store them properly, and to know what to do in case of an accident or breakage. There is no required way to do this, but you should use a system that is clear to those handling the material.
Agreed to the above post. Products you store are low-risk and they are already pre-packaged in secondary and tertiary packaging. However, your Allergen policy should include the Allergens (based on your country's regulation- In USA it is commonly know as BIG-8), training of the employees on Allergen handling, Allergen spillage procedures and procedures to handle utensils for sanitation and employees clothes/shoes after an allergen spill.
Also, you can segregate key areas, with Allergen (color coded) labels in case you store shell eggs, flour bags or any other allergen packaged in loose packaging.
Hope it helps.
You have to identify your allergens - the items inside the cases are already labeled for the consumer - but the facility is required to identify with placards etc. such as the big 8 for instance.
Agreed to the above post. Products you store are low-risk and they are already pre-packaged in secondary and tertiary packaging. However, your Allergen policy should include the Allergens (based on your country's regulation- In USA it is commonly know as BIG-8), training of the employees on Allergen handling, Allergen spillage procedures and procedures to handle utensils for sanitation and employees clothes/shoes after an allergen spill.
Also, you can segregate key areas, with Allergen (color coded) labels in case you store shell eggs, flour bags or any other allergen packaged in loose packaging.
Hope it helps.
Hi FSQA,
I question that a "product" which must be segregated for "safety" reasons can be designated as "Low Risk".
Hi FSQA,
I question that a "product" which must be segregated for "safety" reasons can be designated as "Low Risk".
Charles, I agree that all Allergen containing products should be identified and segregated, however, most of the storage and distribution centers products types (as in this case) are sealed in primary , secondary and sometimes tertiary packaging and as mentioned no reprocessing or exposing of the product is done. My interpretation of the "low risk" was not for the product (as any exposed allergen can be a high risk) , but for the process/cross-contact. Most storage and distribution centers handles SKUs >2000+ product types, with multiple products (in limited quantities) containing more than one allergen in each product type, which can be an issue while storing and distributing the product/s if you plan to segregate all Allergen containing products.
Definitely, there are concerns of frozen/fresh fish, shell eggs, flour in bags and other similar products, which are high risk and should be segregated and should not be stored over any other products.
Charles, I agree that all Allergen containing products should be identified and segregated, however, most of the storage and distribution centers products types (as in this case) are sealed in primary , secondary and sometimes tertiary packaging and as mentioned no reprocessing or exposing of the product is done. My interpretation of the "low risk" was not for the product (as any exposed allergen can be a high risk) , but for the process/cross-contact. Most storage and distribution centers handles SKUs >2000+ product types, with multiple products (in limited quantities) containing more than one allergen in each product type, which can be an issue while storing and distributing the product/s if you plan to segregate all Allergen containing products.
Definitely, there are concerns of frozen/fresh fish, shell eggs, flour in bags and other similar products, which are high risk and should be segregated and should not be stored over any other products.
Hi FSQA,
OK, thks, I agree.
BRC handles this through classifying Process Zones. Theoretically intended, I think, to simplify the "Risk Confusion", in practice seems to have generated a new set of perplexities.