14 replies to this topic

[StevieP]

Evening everyone,

I'm after a bit of advice, I work for a traditional bakery that currently produces vegetarian products and non-vegetarian products such as flapjacks, cookies, muffins etc. There is appetite on site to start looking a vegan product, and so wondered if anyone's got any best practice guidance on the processes I would have to carry out to ensure vegan products aren't compromised. We would be starting from scratch in an existing factory.

 

Welcome your thoughts.

 

Thanks

 

 

[zanorias]

Hi Stevie,

My factory has traditionally specialised in cooked meat products but has entered the vegan market in the past few years and have a few vegan lines now, alongside our usual meat based products. To manage this and the obvious hazard, we have designated PPE and equipment for vegan products which have their own colour code and storage locations. For the few bits of machinery that are used at times for both vegan and non-vegan, everything is ATP swabbed before use. We also do vegan testing via laboratory on the vegan lines. And we have a separate HACCP plan for vegan.

You'd think starting vegan lines in a meat factory would be a headache, but it works out with the sufficient cleaning and segregation processes in place, and our customers, BRC and EHO are happy with it. So I don't see why it can't be feasible for your bakery products.

[StevieP]

Hi zanorias,

makes perfect sense to me. The only question I have, which maybe missing something, regarding your HACCP plan. Do you have a generic HACCP that covers all your vegan products, or have you had to create a separate HACCP for each recipe type? I'm assuming you've created a haccp mainly to identify the potential cross contamination risks rather than the food safety risks as vegan is more of a life-style choice...

 

did you use anything reference documents, websites, institutions for advice?

[SQFconsultant]

I would start by contacting a VEGAN certification body and getting a copy of their code for food manufacturers.

[mgourley]

I'd start with any regulatory/auditing bodies that certify vegan.

Once you see what the requirements are, you can do a GAP analysis against your current process.

We do various "regular", gluten free and Organic products on a couple of bakery lines. We follow the requirements, and all is good.

 

Marshall

[StevieP]

I would start by contacting a VEGAN certification body and getting a copy of their code for food manufacturers.

Thanks, I will look into this and explore the options.

 

THanks,

[pHruit]

Assuming you're in the UK then I'd contact the Vegan Society if you're wanting to put the logo etc on your labels.

If you're doing any own-label for retail then also reach out to the retailers, as they have slightly differing expectations, risk assessment processes etc.

Even if you're not planning to do vegan for them, it will (a) give you access to more information on it, and (b) potentially generate extra business for you when they become aware it's something you're working on

 

I'd also reach out to your ingredients suppliers sooner rather than later, as just because common sense says an ingredient will be vegan-suitable this alas does not mean it is definitely so.
I don't think I can post a Vegan Soc declaration here as they're copyrighted documents, and similar for the bits of the retailer risk assessments that we see (we're an ingredient supplier, so currently one step removed), but for your ingredient suppliers I'd be asking questions like:

• Is your ingredient already certified by the Vegan Society or equivalent? (This will almost certainly be a no, as certification seems to only really exist at the finished product level currently)
• Does the product intentionally contain any animal derivatives?
• Are any processing aids derived from animals used in the manufacture of the product?
• Does the manufacturing site handle any animal derivatives?
• If so, how are these segregated?
• Is there any shared use of equipment with animal products?
• Have you validated the cleaning and segregation controls for removal of traces of animal ingredients?
• If yes, please detail method / frequency / who conducts the tests, and attach results / cleaning validation exercise
• Do you have a process to ensure that all raw materials and processing aids used in the product are suitable for vegans?

If you go down the Vegan Society route you will also need to consider animal testing, as whilst there has been a massive rise in veganism based on sustainability / reduced meat consumption, the Vegan Society's position is understandably still more of the traditional "ethical" basis for veganism. The Vegan Society will give you declarations for your suppliers to complete for each ingredient, but personally I'd want to know as early as possible if this is potentially going to be an issue as it will give more time to consider reformulation / alternative sourcing options. Again, it seems obvious that food ingredients aren't tested on animals, but it's alas not necessarily that clear-cut - discussion on one example in this thread: https://www.ifsqn.co...n-on-packaging/

[karina.j]

Dear Stevie

 

I have done some research regarding vegan trademark for my bakery in UK.

The conclusion at the end was you pay a fee to use a trademark and it is ok to put warning product 'may contain' products of animal origin.

 

Let me explain as this was very interesting exercise for me

this was a response from the v.society :

 

We don’t ask for any specific verification, however we ask you to confirm that procedures are in place to avoid cross contamination on your shared lines as far as is possible and practicable.

 

Because we have egg in every product we were interested in cleaning validation/testing regime for the trademark and we asked for the clarification of the information present on the website can we put 'may contain egg' statement as an allergen statement due to egg present everywhere.

on the webiste you can find:

There is no legal definition of the term vegan, but the FSA provides voluntary guidance on the use of the terms vegetarian and vegan in food labelling, including advice about cross-contamination. They suggest that “manufacturers, retailers and caterers should be able to demonstrate that foods presented as 'vegetarian' or 'vegan' have not been contaminated with non-vegetarian or non-vegan foods during storage, preparation, cooking or display”. However, The Vegan Society is not against foods labelled as vegan also carrying a ‘may contain’ warning about animal allergens.

 

the answer was:

 

That’s correct, provided there are procedures in place to avoid cross contamination on shared lines you are able to register products that carry ‘may contain’ warnings, as in this case, egg is not an intentional ingredient added to the product.

 

and its like seriously? if you look at vegan as lifestyle this might be ok then...

but what do I know...

 

It is different if you do product under retailers name as they require documented procedures to

- assess all raw materials, including processing aids and carriers, 

- incorporate risk assessment to determine methods of verifying vegan suitability,

- include testing if appropriate

 

therefore everything depends on the product and customer it is made for

 

karina

[pHruit]

the answer was:

 

That’s correct, provided there are procedures in place to avoid cross contamination on shared lines you are able to register products that carry ‘may contain’ warnings, as in this case, egg is not an intentional ingredient added to the product.

 

and its like seriously? if you look at vegan as lifestyle this might be ok then...

but what do I know...

 

 

This isn't as crazy as it sounds - IIRC the cross-contamination statement for ingredients being used in Vegan Soc certified products requires that you "diligently strive to minimise cross-contamination from animal substances as far as is reasonably practicable" or similar. It's coming at it from an ethical position of not wanting to eat animals, but recognises that absolute absence is a tricky thing in reality.

The retailers' position of treating vegan claims in broadly the same way as a nut free claim is arguably a more defensive stance, and a cynic might wonder if it's motivated more by a desire to avoid further "turkey DNA detected in vegan ready meals" headlines than to align with the ideals of the Vegan Society and more "traditional" veganism 

Whether this is achievable in practice is an interesting question. Consider the harvesting and processing systems used for ingredients produced on an industrial scale - it's reasonably probable that some bugs will get harvested with wheat and milled into flour, and if you've ever handled any significant amount of IQF softfruits/berries (very difficult to wash effectively without damaging the fruit) then you'll be fairly certain that some batches of products made from these will contain a small amount of slug or snail.

If you're making it in your own kitchen using fresh raspberries then it's easy to avoid, but if you're buying e.g. buying puree from someone processing tens of tons at a time then less so. It is therefore foreseeable that such a product could fail the "is animal DNA detectable?" test - does that mean all industrial-scale foods are non-vegan (and possibly not even vegetarian) on the basis that it's never possible to validate total absence, and that there is an identifiable potential route of contamination that can't really sensibly be completely addressed?

I say this as a vegetarian who has just taste-panelled a raspberry puree. I find a bit of slug really rounds out the flavour, and the extra protein won't do me any harm 

 

Egg is understandably treated differently due to the additional allergen considerations, although on that front it's also the case that "may contain" is also not a formal legal labelling requirement - 1169/2011 does not contain any provision for this (only for allergenic ingredients/processing aids, and cross-contamination is neither of these), but equally no food brand wants to (a) risk making anyone ill, or (b) go to court and try to actually have a precedent set in case law regarding where cross-contamination actually sits in legal terms (e.g. with regard to the "took all reasonable precautions and exercised all due diligence" aspect of the Food Safety Act).

Given how widely these "may contain" declarations are referred to as "alibi statements", I think most brands will acknowledge they're more about legal backside-covering than they are about the actual ingredients of a product

[StevieP]

Thanks for all this information, provides me with a lot to think about! pHruit & karina.j

[doczepi]

Hi Stevie,

My factory has traditionally specialised in cooked meat products but has entered the vegan market in the past few years and have a few vegan lines now, alongside our usual meat based products. To manage this and the obvious hazard, we have designated PPE and equipment for vegan products which have their own colour code and storage locations. For the few bits of machinery that are used at times for both vegan and non-vegan, everything is ATP swabbed before use. We also do vegan testing via laboratory on the vegan lines. And we have a separate HACCP plan for vegan.

You'd think starting vegan lines in a meat factory would be a headache, but it works out with the sufficient cleaning and segregation processes in place, and our customers, BRC and EHO are happy with it. So I don't see why it can't be feasible for your bakery products.

Hi Zanorias..just wondering,have you done a full risk analysis,created a HACCP table,flow diagram  etc for the vegan products? We have all that for our cooked meat products too but where did you start in general?

[Carlos Leoncini]

Regarding vegan reqs compliance, a great deal of the public will be satisfied if the product they buy is vegan suitable or if you like, a product that is “vegan enough”. I wonder if there is any list of minimum requirements to achieve vegan suitable category. I am thinking on small businesses that will not be willing to pay the cost of a certification or maybe those that has not the resources to implement a certifiable management system.

 

Just to give an example: all ingredients are labeled according actual regulation, ingredient storage prevents obvious cross contamination, all ingredients have a technical data sheet, production line is not shared with animal ingredient products, cleaning procedures are minimally written or cleaning instructions are known within line operators, cleaning products are free of animal ingredients, etc…

 

It is important to determine which is the final cut.

Thanks

 

[egonwie79]

Evening everyone,

 

I'm after a bit of advice, I work for a traditional bakery that currently produces vegetarian products and non-vegetarian products such as flapjacks, cookies, muffins etc. There is appetite on site to start looking a vegan product, and so wondered if anyone's got any best practice guidance on the processes I would have to carry out to ensure vegan products aren't compromised. We would be starting from scratch in an existing factory.

 

 

 

Welcome your thoughts.

 

 

 

Thanks

1) You will need a certification body that will certify your vegan claim

their requirements

- Validation of your cleaning programs through allergen testing to shows lines are not compromise

- Employee training

- Line segregations

- Proper review of ingredient used to ensure no sub ingredients from a non vegan source is present

- PPE

- Vegan certification company require to certify the claim

- Finished product testing( Product can go under positive release)

- Scheduling vegan products first before non vegan products if same lines are used

[SQFconsultant]

Im a vwgaterian and we work with both forms. For VEGAN you need absolute seperation controls to avoid contamination... such as no diary, eggs, etc.

I would be very concerned about also handling any meat in same facility

[Carlos Leoncini]

Hi. I think that this is exactly the picture of success about how the management system should look like but in the real world we can see that maybe 70% or more of the veg businesses are small to medium. Big certification companies have already seen the glitter that comes from coin in these opportunity market that is growing faster and faster every day. But certifications are oftenly expensive are difficult to achieve for small businesses due to structucture and resources factors.The question is, what should be the minimum reqs so the consumer can reach a real veg product? If we don’t find an intermediate answer: 1) only the rich will be fed real vegan or 2) many will be fed with faky veg foods.

 

1) You will need a certification body that will certify your vegan claim

their requirements

- Validation of your cleaning programs through allergen testing to shows lines are not compromise

- Employee training

- Line segregations

- Proper review of ingredient used to ensure no sub ingredients from a non vegan source is present

- PPE

- Vegan certification company require to certify the claim

- Finished product testing( Product can go under positive release)

- Scheduling vegan products first before non vegan products if same lines are used