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SQF Module 2 (2.8.1 allergen management)


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gomez89

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Posted 18 September 2019 - 05:45 PM

Good Afternoon everyone, 

I need help understanding this report from our SQF counselor. 

 

The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented.  The allergen management program shall include:
i. A risk analysis of those raw materials, ingredients and processing aids, including food grade lubricants, that contain food allergens;
ii. An assessment of workplace-related food allergens from locker rooms, vending machines, lunch rooms, visitors;
iii. A register of allergens which is applicable in the country of manufacture and the country (ies) of destination if known;
iv. A list of allergens which is accessible by relevant staff.
v. The hazards associated with allergens and their control incorporated into the food safety plan.
vi. A management plan for control of identified allergens.
The allergen management program shall include the identification, management, and labelling of products containing gluten, where applicable. Minor i. Risk analyis not conducted iii. Register of allergens not on file iv. List of allergens acessible not listed v. Hazards associated with allergens not listed vi. Allergen managemetn program not implemented Provision shall be made to clearly identify and segregate foods that contain allergens.  Segregation procedures shall be implemented and continually monitored. Minor methods not listed Where allergenic material may be intentionally or unintentionally present, cleaning and sanitation of product contact surfaces between line changeovers shall be effective, appropriate to the risk and legal requirements, and sufficient to remove all potential target allergens from product contact surfaces, including aerosols as appropriate, to prevent cross contact.  Separate handling and production equipment shall be provided where satisfactory line hygiene and clean-up or segregation is not possible. Minor methods not listed

 

Can someone please explain to me, what I'm missing. I know a few of you will tell me to ask him but I just don't understand what he means still.

Thank you in Advance



QAGB

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Posted 18 September 2019 - 05:53 PM

Good Afternoon everyone, 

I need help understanding this report from our SQF counselor. 

 

The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented.  The allergen management program shall include:
i. A risk analysis of those raw materials, ingredients and processing aids, including food grade lubricants, that contain food allergens;
ii. An assessment of workplace-related food allergens from locker rooms, vending machines, lunch rooms, visitors;
iii. A register of allergens which is applicable in the country of manufacture and the country (ies) of destination if known;
iv. A list of allergens which is accessible by relevant staff.
v. The hazards associated with allergens and their control incorporated into the food safety plan.
vi. A management plan for control of identified allergens.
The allergen management program shall include the identification, management, and labelling of products containing gluten, where applicable. Minor i. Risk analyis not conducted iii. Register of allergens not on file iv. List of allergens acessible not listed v. Hazards associated with allergens not listed vi. Allergen managemetn program not implemented Provision shall be made to clearly identify and segregate foods that contain allergens.  Segregation procedures shall be implemented and continually monitored. Minor methods not listed Where allergenic material may be intentionally or unintentionally present, cleaning and sanitation of product contact surfaces between line changeovers shall be effective, appropriate to the risk and legal requirements, and sufficient to remove all potential target allergens from product contact surfaces, including aerosols as appropriate, to prevent cross contact.  Separate handling and production equipment shall be provided where satisfactory line hygiene and clean-up or segregation is not possible. Minor methods not listed

 

Can someone please explain to me, what I'm missing. I know a few of you will tell me to ask him but I just don't understand what he means still.

Thank you in Advance

 

It might help to clarify what your current program looks like. Can you give us a summary of your allergen control program? Then maybe we can match that up with your SQF counselor/consultant's results. 



gomez89

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Posted 18 September 2019 - 05:59 PM

It's hard to tell which is our allergen program, we are a facility that only stores frozen items. The way it comes in is the way it leaves our facility. We are a third party holder mostly for all our clients. Clients product comes palletized and wrapped, and all we do is gold them here until they find a buyer. By what our consultant was suggesting is the isolate all product that has an allergen from all other product. I mean I feel like I'm getting everyone confused and myself too. 



gomez89

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Posted 18 September 2019 - 06:05 PM

This is our SOP we created for allergen. Can someone take a look and help me with what I am missing. 

 

Attached File  2.8.1 allergens.docx   41.79KB   174 downloads

 



arahman

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Posted 18 September 2019 - 06:08 PM

Do you hold any of these products below? What is your cross-contamination prevention plan?

 

How are they sealed? arre they labelled? is their designation operate storage for allergens?

cleaning methods and validation?  training? 

are non-food lubricants/products kept separate and labelled from food products?

Is there a process flow map? receiving-->storage-->shipping...e.t.c?

Have you identified possible areas of cross-contamination? 

 

  1. Milk
  2. Eggs
  3. Fish (e.g., bass, flounder, cod)
  4. Crustacean shellfish (e.g., crab, lobster, shrimp)
  5. Tree nuts (e.g., almonds, walnuts, pecans)
  6. Peanuts
  7. Wheat
  8. Soybeans


gomez89

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Posted 18 September 2019 - 06:15 PM

Yes, I'm positive that we have a few of the items above. So what we did start is separating all product with allergen. All product is sealed and it box and with labels. We do have a process of receiving storage and shipping. We never open boxes that have the clients product inside. Our freezer is below 30. 



QAGB

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Posted 18 September 2019 - 06:23 PM   Best Answer

It's hard to tell which is our allergen program, we are a facility that only stores frozen items. The way it comes in is the way it leaves our facility. We are a third party holder mostly for all our clients. Clients product comes palletized and wrapped, and all we do is gold them here until they find a buyer. By what our consultant was suggesting is the isolate all product that has an allergen from all other product. I mean I feel like I'm getting everyone confused and myself too. 

 

I understand. So it looks like you don't actually have an allergen program in place. Please see my responses below in the burgundy font. 

 

  • Risk analyis not conducted - You should create a risk assessment for how your employees handle allergens vs. non-allergens, which would include severity and likelihood of the potential hazards. The risk assessment also includes how your program mitigates those risks. For example...."punctures/damage to allergen containing products in your warehouse. The severity of this has the potential to be medium, or high depending on how your products are stored. If other products become contaminated, the potential for further contaminating goods as they travel and reach other facilities is certainly present. Also, I would assess this as medium or high likelihood, since people are known to be careless with forklifts and can damage product. Your mitigation techniques for this kind of risk should include storage of product (storing non-allergens above allergens) and/or separating entirely your allergens from non-allergens (storing like products together). You should also consider using allergen labeling on your pallets to help identify products which have allergens. Making sure all employees inspect incoming products for damage before they are removed from the trailer or container, and making sure employees are trained on how to use forklifts.

 

  •  Register of allergens not on file - I believe this is talking about the register of allergens "regulated" by countries you import/export to. For example, the US has the big "8" allergens, while Canada has a more extensive list. You should have a register of those allergens and which ones apply to your products. 

 

  • List of allergens acessible not listed - this is a master list of allergens you handle. You can do this by product/SKU, and list the allergens identified in each one in a big document that your employees can access. That way they know what allergens are present, and so they can  use extra caution in handling them.

 

  •  Hazards associated with allergens not listed - This is the hazard analysis part of your Food Safety Plan. You should be assessing allergens (usually under the chemical category) in your Food Safety Plan. Some people (including myself) combined the Food Safety Plan with the HACCP Plan.

 

  • Allergen managemetn program not implemented Provision shall be made to clearly identify and segregate foods that contain allergens.  Segregation procedures shall be implemented and continually monitored. This is where you identify and properly store your foods with allergens. Allergens should always be stored below non-allergens in your warehouse to reduce contamination in the event of damage to pallets. You should also identify any special handling of allergens, and what to do in the event of a spill.  

 

  • Where allergenic material may be intentionally or unintentionally present, cleaning and sanitation of product contact surfaces between line changeovers shall be effective, appropriate to the risk and legal requirements, and sufficient to remove all potential target allergens from product contact surfaces, including aerosols as appropriate, to prevent cross contact.  - You aren't really doing any production, but you should identify as per above, what to do in the event of a spill. You will want to have a process to make sure that allergens are contained and contamination prevented (which will certainly include cleaning and sanitation).

 

  • Separate handling and production equipment shall be provided where satisfactory line hygiene and clean-up or segregation is not possible. - I can't think of how this would really apply to you...because you should be able to clean-up and segregate where needed.


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gomez89

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Posted 18 September 2019 - 06:34 PM

Thank you, very much. This really helps.



SQFconsultant

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Posted 18 September 2019 - 10:27 PM

Excellent reply QAGB!


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

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Charles.C

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Posted 19 September 2019 - 01:33 PM

Maybe have a look at the Free Guidance material ?


Kind Regards,

 

Charles.C


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