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Advice on Allergen segregation for a chiller / cooled room

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#1 StevieP

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Posted 15 July 2019 - 01:39 PM

Good afternoon everyone,

I’m after some advice from you if possible. I work for a small ambient bakery that manufacture; flapjacks, cookies, muffins, gingerbread etc. I’ve recently established that work in process that is cooled in the site cold room/chiller is not managed from an allergen perspective. E.g. Nut products (work in progress) are stored on a wall (that’s signed). However, non nut products are stored around them, and in some cases, empty trays and racks. My concern is one of cross contamination.

I guess the question is, how do you control the cross contamination risk? Do you use physical barrier segregation, or something else? There would always be non-nut products in this area, but not always nut based products.

I clearly need to put in place a process based on risk verus likelihood x severity.

Welcome your thoughts.



#2 freshandsafe

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Posted 15 July 2019 - 04:23 PM

One simple rule you could include is no allergen is stored above an unlike allergen or non-allergenic product.


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I would be happy to help in your process.

 

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#3 The Food Scientist

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Posted 15 July 2019 - 05:00 PM

By non-nut products, is there another allergen associated with those? Or are they completely allergen free? I would imagine everything you make contains at least one allergen. So make sure you store like allergens on top of each other. if there is a non-allergen you can store it on top of the allergen, and not vice versa. Of course signage if very important. Physical segregation would be designated racks for non-nut and nut, you can color code and post signs. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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#4 SQFconsultant

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Posted 15 July 2019 - 07:34 PM

You control with physical barrier. You can not put a rack of 20 trays of walnut chocolate chip cookies in a room to cool right next to a rack of blueberry coconut muffins even if they have plastic sheeting on them. Physical separation is need - wall.


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#5 zanorias

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Posted 15 July 2019 - 08:06 PM

Hi Stevie,

Is there an accreditation scheme you are with?

I don't store stock that has an allergen on top of a product that does not contain that allergen. Clear allergen labels on stock containing allergens. Quarantine and cleaning procedure in the event of a spill.(we are UK based manufacturer with BRC).
Ideally you could have separate areas for different allergens but then may not be physically feasible with space, and some things have multiple allergens and so on.
For your chiller, I would recommend not storing non-nut products or equipment beneath the nut containing product and adjacent segregation as much as space permits.



#6 pHruit

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Posted 16 July 2019 - 09:33 AM

It's the least easy to implement, but I have to say I agree with Glenn's suggestion.

 

In terms of the "allergens always on lower racks" approach, this is obviously good practice, but it sounds like the chiller may be multiple purpose in terms of storing both raw materials and (semi-)finished products? May also therefore need to think about best practice for "cooked"/raw segregation, which will add further complexity, although this may be less applicable depending on what constitutes "raw" (or semi-finished) for your process.

If full physical segregation isn't possible then some defined division of storage space will probably be essential.

Would I be correct in assuming that your products are open/unsealed at this stage? That certainly increase potential risk level, so if they can't have their own physically segregated area then I'd be looking at what can be done to accomplish this on a smaller scale.

 

The other point that would make me nervous in your position is the potential for people cutting corners to save themselves time. Do you have a rule about e.g. hand washing / PPE change between handling product with/without nuts? It could be quite difficult to monitor/enforce this if people are easily able to put down a tray of nut product and pick up a tray of non-nut product from adjacent racking.

Obviously there is always an extent to which we have to rely on our colleagues, but I'm generally of the view that wherever possible critical tasks should be as simple as possible and designed to make it harder to cut corners than to do it properly.

In any case I'd put in plenty of extra time on allergen training - it is gradually getting a bit easier as some incidents have had fairly significant coverage in the news/media, schools in the UK seem to be very much more attentive to such things etc, and thus there is more general awareness, but it can't hurt to reinforce best practice and definitely to make sure that everyone fully understands whatever new control system you implement.



#7 StevieP

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Posted 16 July 2019 - 12:00 PM

You control with physical barrier. You can not put a rack of 20 trays of walnut chocolate chip cookies in a room to cool right next to a rack of blueberry coconut muffins even if they have plastic sheeting on them. Physical separation is need - wall.

 

 

Thanks, the physical barrier was my thoughts too.



#8 StevieP

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Posted 16 July 2019 - 12:05 PM

Hi Stevie,

Is there an accreditation scheme you are with?

I don't store stock that has an allergen on top of a product that does not contain that allergen. Clear allergen labels on stock containing allergens. Quarantine and cleaning procedure in the event of a spill.(we are UK based manufacturer with BRC).
Ideally you could have separate areas for different allergens but then may not be physically feasible with space, and some things have multiple allergens and so on.
For your chiller, I would recommend not storing non-nut products or equipment beneath the nut containing product and adjacent segregation as much as space permits.

 

Hi zanorias,

The chiller is for WIP Racks and trays of products, we don't have the ability to store on top of each other. Reading your comments, makes sense to Raw Ingredient Allergens. I think that I would need to go with SQFconsultant's comments around physical segregation using barriers in the chiller to protect Non-Nut WIP from Nut WIP.

 

Out of interest, does anyone have any guidance around which allergen is more significant than others. Clearly Nuts are, nut which is next on the allergen higher archy?



#9 StevieP

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Posted 16 July 2019 - 12:07 PM

It's the least easy to implement, but I have to say I agree with Glenn's suggestion.

 

In terms of the "allergens always on lower racks" approach, this is obviously good practice, but it sounds like the chiller may be multiple purpose in terms of storing both raw materials and (semi-)finished products? May also therefore need to think about best practice for "cooked"/raw segregation, which will add further complexity, although this may be less applicable depending on what constitutes "raw" (or semi-finished) for your process.

If full physical segregation isn't possible then some defined division of storage space will probably be essential.

Would I be correct in assuming that your products are open/unsealed at this stage? That certainly increase potential risk level, so if they can't have their own physically segregated area then I'd be looking at what can be done to accomplish this on a smaller scale.

 

The other point that would make me nervous in your position is the potential for people cutting corners to save themselves time. Do you have a rule about e.g. hand washing / PPE change between handling product with/without nuts? It could be quite difficult to monitor/enforce this if people are easily able to put down a tray of nut product and pick up a tray of non-nut product from adjacent racking.

Obviously there is always an extent to which we have to rely on our colleagues, but I'm generally of the view that wherever possible critical tasks should be as simple as possible and designed to make it harder to cut corners than to do it properly.

In any case I'd put in plenty of extra time on allergen training - it is gradually getting a bit easier as some incidents have had fairly significant coverage in the news/media, schools in the UK seem to be very much more attentive to such things etc, and thus there is more general awareness, but it can't hurt to reinforce best practice and definitely to make sure that everyone fully understands whatever new control system you implement.

Hi pHruit,

The chiller is just for WIP and not Raw Ingredients. In my head, I'm thinking barrier protection around Nut products is probably what we should be doing.



#10 majoy

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Posted 16 July 2019 - 03:18 PM

In an ideal QA world, physical wall barrier inside the cooler or separate cooler for allergen and non-allergen is the best option.

 

But... is this something your management willing to invest on? especially you are already storing both allergen and non-allergen together? i'm assuming you are GFSI scheme certified and have passed audits while this practice is on-going? Is this finding a major NC on your 3rd party audit or customer audit?

 

Well we are always quick to suggest best option but in the real world, construction takes time, resources is very limited unless there is a driving force from customer or there is a risk of failure from an audit or withdrawal of certificate which will result to loss customer = loss sales. Life of QA, always fighting for what is right. [sorry a bit venting here].

 

If construction of a wall barrier is in the long term, i suggest space segregation left side/non-allergen, right side/allergen. You can even go to the extent of rack covers (but defeats the purpose of cooling really, plus you have to make sure that covers are clean etc.) if cooling these WIP are only approx few hours, then production scheduling can also be an option so the allergen/non-allergen products does not meet inside the cooler of course you have to produce the non-allergen first.


"Whatever you do, do it well..." - Walt Disney


#11 The Food Scientist

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Posted 16 July 2019 - 03:40 PM

In an ideal QA world, physical wall barrier inside the cooler or separate cooler for allergen and non-allergen is the best option.

 

But... is this something your management willing to invest on? especially you are already storing both allergen and non-allergen together? i'm assuming you are GFSI scheme certified and have passed audits while this practice is on-going? Is this finding a major NC on your 3rd party audit or customer audit?

 

Well we are always quick to suggest best option but in the real world, construction takes time, resources is very limited unless there is a driving force from customer or there is a risk of failure from an audit or withdrawal of certificate which will result to loss customer = loss sales. Life of QA, always fighting for what is right. [sorry a bit venting here].

 

If construction of a wall barrier is in the long term, i suggest space segregation left side/non-allergen, right side/allergen. You can even go to the extent of rack covers (but defeats the purpose of cooling really, plus you have to make sure that covers are clean etc.) if cooling these WIP are only approx few hours, then production scheduling can also be an option so the allergen/non-allergen products does not meet inside the cooler of course you have to produce the non-allergen first.

 

I agree with you, sometimes it is costly, and you have limited space, In an ideal QA world (where top management are always open to our suggestions, which is almost never), I have always done what you mentioned in my facilities and auditors were always okay with it as long as you actually separate (left/right) and label. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#12 Charles.C

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Posted 18 July 2019 - 12:16 AM

As per previous posts, it usually comes down to assessing risk of cross-contamination and the specific products/process.

 

Physical barriers everywhere may be ideal but total isolation, eg walls, is not always mandatory, eg -

 

Attached File  Kraft allergen management.pdf   2.77MB   54 downloads

 

@StevieP - IMO you need to do some sampling/analysis. Numbers speak volumes.


Kind Regards,

 

Charles.C


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#13 moskito

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Posted 18 July 2019 - 11:47 AM

Hi,

 

i agree with Charles, IMO segregation does not necessarly mean that physical separation e.g. with a wall is mandatory. It works since many years w/o problems in operation based on our risk assessment and our allergen policy where we don't have separate rooms.

No problems with IFS/BRC.

 

Rgds

moskito







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