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How does a facility transition to "treenut free"?

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avnerbez

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Posted 17 September 2019 - 10:35 PM

How does a facility become "peanut/treenut free"?

 

Ours is a wet product (hotfill of sauces, marinades, etc.) and I wanted to know how might one transition from being a facility that handled treenuts sometimes to one that can claim to be treenut free?  Would a facility dealing in wet product be safer than facilities in which dry versions of the products were handled?

 

Has a facility ever been able to claim it is "tree nut free" if particular precautions are taken during and after packing a product with tree nuts as an ingredient in some form?  An example might be an almond butter or a coconut amino.  

 

I am eager to learn more about what might be possible and if anyone has encountered something like this in the past.

 

 

 

 



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Posted 18 September 2019 - 10:53 AM

Hi Avnerbez

 

If the facility makes products which contain tree nut as an ingredient and these tree nets are store n site than facility cannot claim to be tree nuts free.

The best you can do to segregate the nuts storage from other ingredients and make the nuts containing products on some specific lines.

This may give you chance to claim that "This Products is made on allergens free production line"

 

One other option is to 



QAGB

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Posted 18 September 2019 - 12:37 PM

How does a facility become "peanut/treenut free"?

 

Ours is a wet product (hotfill of sauces, marinades, etc.) and I wanted to know how might one transition from being a facility that handled treenuts sometimes to one that can claim to be treenut free?  Would a facility dealing in wet product be safer than facilities in which dry versions of the products were handled?

 

Has a facility ever been able to claim it is "tree nut free" if particular precautions are taken during and after packing a product with tree nuts as an ingredient in some form?  An example might be an almond butter or a coconut amino.  

 

I am eager to learn more about what might be possible and if anyone has encountered something like this in the past.

 

 

I don't believe you can claim to be tree nut free if you do handle/pack products containing tree nuts.

 

As far as transitioning to a tree nut free facility, I don't know much about that other than to say you would have to first stop handling products containing tree nuts. I would also think you'd have to do a very detailed sanitation process, including all equipment, floors, walls, etc. in the area where this was produced, and would need to validate that your cleaning completely removed the tree nut proteins from that area before you could even think about making such a claim.



avnerbez

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Posted 18 September 2019 - 03:00 PM

I don't believe you can claim to be tree nut free if you do handle/pack products containing tree nuts.

 

As far as transitioning to a tree nut free facility, I don't know much about that other than to say you would have to first stop handling products containing tree nuts. I would also think you'd have to do a very detailed sanitation process, including all equipment, floors, walls, etc. in the area where this was produced, and would need to validate that your cleaning completely removed the tree nut proteins from that area before you could even think about making such a claim.

 

There was no desire to claim to be tree nut free if the facility was not.  Removal of treenuts from the facility is a given.  But if one desired to move towards making a tree nut free claim, what would the validation process look like?  Might it look like an Environmental Monitoring Program?  And do you know what tests would be required to test for a tree nut protein?

Your response (thank you, by the way) brought up another hypothetical question.  Can someone call their line "tree nut free" if there are comprehensive sanitation (CIP) procedures and ATP swabbing has shown there has never been a protein contamination after sanitation?  Or might one go an extra step and require a breakdown cleaning of the line after the packing of a contaminating allergen ingredient?



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Posted 18 September 2019 - 03:43 PM

I've worked in a plant which used to pack nuts but then had no claim (so moved to not saying "free from" but not saying "may contain" either.)  They did this before my time but in my view it has to be thorough, thorough cleaning and ELISA swab the heck out of every difficult to clean location.  Then probably produce some free from product and test that too.  If you are then never going to reintroduce nuts to that facility you've proven you no longer need to say "may contain" whether you can then say "free from" feels a bit more nerve wracking to me but logically you've done far more than most changeovers between allergens would do.



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GMO

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Posted 18 September 2019 - 03:44 PM

another hypothetical question.  Can someone call their line "tree nut free" if there are comprehensive sanitation (CIP) procedures and ATP swabbing has shown there has never been a protein contamination after sanitation?  Or might one go an extra step and require a breakdown cleaning of the line after the packing of a contaminating allergen ingredient?

 

I would never claim "free from" if I was using the same packing or production equipment as an ingredient I was trying to make the claim to be free from.  It's too prone to error.



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Posted 18 September 2019 - 03:45 PM

There was no desire to claim to be tree nut free if the facility was not.  Removal of treenuts from the facility is a given.  But if one desired to move towards making a tree nut free claim, what would the validation process look like?  Might it look like an Environmental Monitoring Program?  And do you know what tests would be required to test for a tree nut protein?

Your response (thank you, by the way) brought up another hypothetical question.  Can someone call their line "tree nut free" if there are comprehensive sanitation (CIP) procedures and ATP swabbing has shown there has never been a protein contamination after sanitation?  Or might one go an extra step and require a breakdown cleaning of the line after the packing of a contaminating allergen ingredient?

 

Hi avnerbez,

 

In the case of claiming to be tree nut free - maybe I am misunderstanding this phrasing below. I am reading this as can you claim to be tree nut free if you have taken precautions  such as "allergen verification and validation of equipment".

 

 

 

 

Has a facility ever been able to claim it is "tree nut free" if particular precautions are taken during and after packing a product with tree nuts as an ingredient in some form?  An example might be an almond butter or a coconut amino.  

 

 

 

 

As to the rest of the validation process, yes, it would look similar to an Environmental Monitoring Program. You would need to build out all of the areas that need to be tested. Neogen does have a laboratory that can do quantification testing for you. I believe you'd need to have sponge swabs sent to them (but you can ask Neogen more about that). I'm not sure if they provide you with a test kit including sponges, or if you can just buy the sponges from a lab supplier, so you can ask Neogen more about that as well. Other recognized labs will also do allergen testing, but they use Neogen testing methods typically (so you can just cut out the middle man and work directly with Neogen).

 

Neogen has different tests per protein type. I know that when I've used their lateral flow devices, they had specific flow devices for the protein type (tree nut is one - according to their website). However, in your case, since you need to conduct validation, you would need your tests quantified by a lab; whereas the lateral flow devices are used for verification. When I did allergen validation, I used our finished product as the validation material, so I didn't use any swabs or sponges for validation. I did use the lateral flow devices and ATP tests to do equipment verification while doing this.

 

I would not call a line tree nut free even after doing CIP and ATP. If you pack tree nut containing products on that line, I don't think you can truly consider it tree nut free. 



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Posted 18 September 2019 - 04:28 PM

 

Neogen has different tests per protein type. I know that when I've used their lateral flow devices, they had specific flow devices for the protein type (tree nut is one - according to their website). However, in your case, since you need to conduct validation, you would need your tests quantified by a lab; whereas the lateral flow devices are used for verification. When I did allergen validation, I used our finished product as the validation material, so I didn't use any swabs or sponges for validation. I did use the lateral flow devices and ATP tests to do equipment verification while doing this.

 

I would not call a line tree nut free even after doing CIP and ATP. If you pack tree nut containing products on that line, I don't think you can truly consider it tree nut free. 

 

Can you explain "lateral flow devices" for me.

 

I wouldn't dream of calling a line "tree nut free" after CIP and ATP.  For us we just call that "end of the day". 

I was thinking more along the lines of CIP, intensive breakdown sanitation, then intensive ATP.  How quickly can allergen testing get results?  Perhaps allergen testing for verification before running anything tree nut free.  

 

I don't think it would be possible.  I am just trying to find out what has been tried and found successful.   

 

As we expand into co-packing more ingredients we haven't used in the past crop up.  as a pretty wet facility (hotfill bottling) we probably have few points of exposure.  Since we are also mixed use Gluten free, and very occasionally run non-kosher on a kosher line (under "reverse" supervision and with kosherizing after) identity preserevation is a always a priority anyway.



QAGB

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Posted 18 September 2019 - 05:40 PM

Can you explain "lateral flow devices" for me.

 

I wouldn't dream of calling a line "tree nut free" after CIP and ATP.  For us we just call that "end of the day". 

I was thinking more along the lines of CIP, intensive breakdown sanitation, then intensive ATP.  How quickly can allergen testing get results?  Perhaps allergen testing for verification before running anything tree nut free.  

 

I don't think it would be possible.  I am just trying to find out what has been tried and found successful.   

 

As we expand into co-packing more ingredients we haven't used in the past crop up.  as a pretty wet facility (hotfill bottling) we probably have few points of exposure.  Since we are also mixed use Gluten free, and very occasionally run non-kosher on a kosher line (under "reverse" supervision and with kosherizing after) identity preserevation is a always a priority anyway.

 

Lateral flow devices can be found on the Neogen website. They are what is called the "Reveal 3-D" line. If you're familiar with a pregnancy test (sorry for being blunt), then that is pretty similar to what this is. You get 1 Line, 2 Lines, or No Lines to appear after testing depending on your result. It is not quantifiable, just a pass/fail. Therefore, this can only be used as a verification that your process or product is ok (after you've validated your program). We always did allergen testing between runs using visual, ATP, and specific protein testing via lateral flow devices.

 

Validation would require actual quantification (true PPM amounts - hopefully below detection limits). Product (or sponge swabs) would be sent to a lab, and you'd get your results. It may take several days to do one round of testing - it will likely take multiple rounds to complete a validation. I think the quickest turnaround time would be 3-4 business days, because you have to allow for the lab to get the samples in the mail, and then you'd be paying extra for expedited testing.

 

I feel as though I don't truly understand your "tree nut free" questions though. Not that I would ever recommend this, but you can produce a product that doesn't have tree nuts in it on a line that has gone through all the proper sanitations, validations, and verifications. Making any "tree nut free" claims though, I'm not sure you would want to do that. I'd opt in the other direction and state "processed on a line that does process tree nut ingredients" or however that claim's wording is supposed to be.

 

The original question was whether you could transition a company that produced tree nuts, back to a company that is tree nut free. The answer is, probably, if done correctly and thoroughly. I've never done it myself, but you'd definitely have to go through some intense (and expensive) validation processes to conclude you are tree nut free again. Basically, my point is the same as GMO's point above. I'd not be making "tree nut free" claims on a line where tree nut ingredients are used, and I'd only consider my facility tree nut free if and only if I had done enough thorough testing to conclude the facility is totally free of tree nut protein. This is very risky though, and always note that if you end up having a recall for it (or worse), you'd be the one that signed off on it.

 

Also to answer one of your other questions - if your allergens are in a liquid format, they are indeed a lot easier to manage. Airborne allergen powders are more of a risk because they get everywhere. So as you are a wet process (and hopefully the product you are dealing with isn't dehydrated), your validation might be a bit easier than for someone using powdered ingredients.


Edited by QAGB, 18 September 2019 - 05:41 PM.


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Hank Major

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Posted 18 September 2019 - 07:12 PM

Also, from an auditing point of view, to claim that you are tree nut free you would need a written No Tree Nuts Policy, and employees would need to have documented training about what all the tree nuts are, how to avoid purchasing them or otherwise bringing them into the facility, and how to read labels for the presence of tree nuts.



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avnerbez

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Posted 18 September 2019 - 07:37 PM

Thank you.  All very good points and I have learned from the all your answers.



GMO

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Posted 19 September 2019 - 01:41 PM

I was thinking more along the lines of CIP, intensive breakdown sanitation, then intensive ATP.  How quickly can allergen testing get results?  Perhaps allergen testing for verification before running anything tree nut free.  

 

I don't think it would be possible.  I am just trying to find out what has been tried and found successful.   

 

 

I would never claim nut free on a line which has ever been used to run nuts.  I would be confident to not include a nut alibi if some extensive sanitation took place with ELISA (normally about 1 week turnaround) and was never used for nuts again.






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