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Fijiball

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Posted 22 October 2019 - 09:20 AM

Hello Team

 

We produce porridge with peanut butter.After deep clean we use 3 m clean trace for surface protein and the results came negative.But the next product which do not contain peanut which we have send for testing for peanut the results came 2.7 ppm.

 

We state on the labelling. Kitchen also handle peanuts.

 

What is the legal limit for peanut ?

 

Is there any best controls or swabs to eliminate peanut completely.

 

we are a small kitchen with just 1 line .

 

 

Thanks



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Posted 22 October 2019 - 09:57 AM

Hi saenath

 the limit for peanut allergy is 2.7mg/kg

 

kind regards

Humiad Khan



pHruit

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Posted 22 October 2019 - 10:41 AM

There is no specified limit defined for allergens (except sulphites) at a regulatory level in the UK/EU at present - broadly you'd want the result to be below the limit of detection for the test.

Swabbing is possibly open to false negatives, as you're presumably only sampling a part of the surface? A non-homogeneous distribution of residual proteins could therefore give areas where there is no detection, even though other areas are still contaminated. Contamination could of course also come from tools, people etc.

Typically the approach to validation / verification is to test the areas that are most difficult to clean, so you may need to determine what those are for your equipment.

 

Generally you will need controls both in terms of cross-contamination risks (storage, handling, staff PPE etc) and cleaning. The latter will be specific to your site/facilities. Without knowing the specifics of these, as a starting point you may want to discuss with your cleaning chemical provider to check that you're working with the most appropriate chemicals for your situation, and that they're being used correctly.



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Posted 22 October 2019 - 10:46 AM

In the UK, there is no defined limit. The only limits that have been defined so far are for Gluten and Sulpher Dioxide/Sulphites. Australia has different regulations.

 

Have you tried reviewing your cleaning chemicals? Allergen proteins are particularly difficult to remove.

 

We do not handle peanuts so I cannot help any more than that I'm afraid.

 

Good luck!



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Posted 22 October 2019 - 10:49 AM

Thank you all.

 

We are having SALSA audit in 2 weeks. Can i show the auditor the lab results with 2.7mg/kg.

 

THanks



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Posted 22 October 2019 - 10:54 AM

Have you considered scheduling the productions differently so that the peanut containing product is done after everything else and before the nightly clean down? This may help to control contamination. Or is there a possibility of using dedicated equipment for the peanut porridge?

 

You should show the auditor your result provided you have documented and carried out a corrective action within a reasonable timescale and have shown that the action was successful in removing the traces of peanut.

 

We are allowed to have issues, we can't avoid them, it's what you do about the issue that is important, burying it in the back of the cupboard isn't a good plan especially with peanut.


I'm entitled to my opinion, even a stopped clock is right twice a day

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Posted 22 October 2019 - 12:06 PM

Thank you all.

 

We are having SALSA audit in 2 weeks. Can i show the auditor the lab results with 2.7mg/kg.

 

THanks

 

The auditor will probably ask you if you were not aware that the limit in UK is "not detectable" !!


Kind Regards,

 

Charles.C


Charles.C

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Posted 22 October 2019 - 01:07 PM

addendum

 

Interpretation of allergen results can be tricky. Yr problem is that you have a specific, positive, reported level.

 

For example ex-Neogen handbook -

 

14.  Why are the Alert and Reveal test kits set at 5 ppm and 10 ppm?

Because regulators have not set actual thresholds for allergens, the food industry has taken a
proactive approach of self-governance and chosen these levels. They are relevant by minimizing
risk to the consumer, without going to “zero tolerance” as a threshold
.

15.  What does the term “limit of detection” mean? Is it different than “limit of quantitation”?

  A test kit’s limit of quantitation (LOQ) refers to the lowest point that its results are quantifiable. As
a general rule, ELISAs identify this as the first non-zero control in that kit, which is the 2.5 ppm
control in Neogen’s test kits. The limit of detection (LOD) is the lowest point at which a result can
be considered above background noise. A LOD is determined as the mean of 10 evaluations of a
known negative sample, plus two standard deviations. However, results greater than the LOD but
less than the LOQ are analytically valid for qualitative purposes only.

16.  should a sample that tests below 5 ppm on an Alert kit be called “negative”?

  No. As indicated above, the 5 ppm level has been established and generally recognized by the food
industry as an indicator of risk associated with testing. However, levels below 5 ppm do not mean
the sample is negative, as levels between the detection limit and 5 ppm may still be allergenic.
More appropriate would be the phrase: “Below limit of detection (BLD).

17.  What are the allergen kits detecting and how is it reported?

  Each specific test kit detects the presence of residue from the allergenic food of concern. Each test
reports the ppm value to the total allergenic food. For example: peanut results are reported as ppm
of total peanut, as opposed to protein only. See Appendix A for specific allergen information. See
Appendix D for converting allergenic food results to protein results.

18.  Are all manufacturers’ food allergen test kits reporting on the same scale?

  No,  some  manufacturers  report  results  in  ppm  protein,  others  in  ppm  total  allergenic  food.  
Neogen’s Veratox and Alert tests report as the ppm of total allergenic food. Those who prefer to
convert their results from ppm total allergenic food to ppm allergenic protein can do so based on
average protein content of these foods. For example, nonfat dried milk (NFDM) contains approxi-
mately 35% protein. Therefore, a 5 ppm total milk on the Veratox for Total Milk Allergen test would
be approximately 1.75 ppm milk protein. Peanut is approximately 26% protein, so 5 ppm Veratox
for Peanut results would convert to 1.3 ppm protein. See Appendix D for converting allergenic food
results to protein results.

 

 

I am no expert in this area so this is speculation but I think the above means that if the chosen methodology used for yr sample had been "set" at 5ppm limit, yr result would maybe have  been reported as "not detected" (ie < 5ppm). Seems method used in yr case was "super"-sensitive which is presumably preferable from a safety POV

Also see Note 18.

 

PS - here are some methods which claim LOD 0.5 - 1 ppm of peanut so I guess highly sensitive methods do exist for this item particularly in view of its potent allergenic characteristics.

 

https://www.romerlab...rgen-test-kits/

 

I sort of conceptually agree with Trubertq but this demands yr also proving the possibility of non detection. Whether UK would happily accept yr product/data  as is since combined with  inclusion of peanut caveat on label is "problematic".

 

JFI, here is Neogen's suggested approach to controlling an analogous peanut process to yr own.

 

Attached File  peanut.PNG   59.97KB   0 downloads

 


Kind Regards,

 

Charles.C


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Posted 22 October 2019 - 01:30 PM

There is no limit for peanut under UK legislation.  If you find it, there is a risk and you shouldn't be putting it on the market.  "Alibi" labelling (also handles peanuts) is meaningless.  If you gave someone anaphylaxis due to a cross contamination issue, it wouldn't protect you, it wouldn't be classed as due diligence.



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Posted 22 October 2019 - 01:55 PM

There is no limit for peanut under UK legislation.  If you find it, there is a risk and you shouldn't be putting it on the market.  "Alibi" labelling (also handles peanuts) is meaningless.  If you gave someone anaphylaxis due to a cross contamination issue, it wouldn't protect you, it wouldn't be classed as due diligence.

 

So "may contain" labelling is totally unacceptable in UK per se ? Seems improbable ?


Kind Regards,

 

Charles.C


GMO

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Posted 22 October 2019 - 03:10 PM

So "may contain" labelling is totally unacceptable in UK per se ? Seems improbable ?

 

It has no basis in law.  So if you put on "may contain" and then give someone anaphylaxis you have no due diligence. 



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Posted 22 October 2019 - 03:41 PM

The "may contain" / precautionary labelling situation is in a very grey area; there is certainly no formal legal provision for it's use, but it is accepted to an extent by the Food Standards Agency in the UK - see e.g. https://www.food.gov...d-manufacturers and the attached.

There is currently no provision within the labelling regulations to indicate the presence of any allergen other than those added as ingredients or processing aids, and thus it is to an extent left up to food businesses to decide how (or possibly even if!?) they should indicate the potential presence of allergens that could be included through genuinely unavoidable cross-contamination risks. Alas this ambiguity has led to the use of "may contain" on everything from those products where it serves a legitimate purpose, through to others where it's arguably used as what the brand owner hopes will be a legal shield against action that could result from their / their suppliers' poor practices. The term "alibi labelling" is one I see quite frequently used as a synonym for precautionary labelling, and that perhaps characterises the less-than-positive side of the way in which it's used.

 

Understandably it also comes in for criticism from various of the allergy campaign groups, as the lack of clarity around it makes it basically useless as a source of information for allergy sufferers. This is fine if it is a genuine "may contain", but less than ideal if it's a "can't really be bothered to validate/verify proper cross-contamination controls".

 

IMO there is a definite need for proper clear regulation/guidance on this, so that food businesses and consumers both know exactly what is expected and what it means.

 

In the context of the OP's situation, I agree with GMO - I would definitely not be placing the affected batch on the market, as "may contain" is undermined by the result of "definitely contains". My personal view is that this would therefore not satisfy the "reasonable precautions" requirement for a due diligence defence under the Food Safety Act. (with an obligatory "I'm not a lawyer" disclaimer ;) ).

 

 

Attached Files



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Posted 23 October 2019 - 03:31 PM

Could you come one suggest the best swab kits available in UK.

 

Right now we are using 3m Cleantrace protein plus.

 

Thanks



GMO

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Posted 24 October 2019 - 11:04 AM

 

 

Understandably it also comes in for criticism from various of the allergy campaign groups, as the lack of clarity around it makes it basically useless as a source of information for allergy sufferers. This is fine if it is a genuine "may contain", but less than ideal if it's a "can't really be bothered to validate/verify proper cross-contamination controls".

 

 

Agreed.  My son has a nut allergy (a specific nut not all nuts) and if we avoided "may contain nuts" he would not eat.  His allergy is mild, the worst he's had is lip swelling or vomiting, but it's never guaranteed that this is the only reaction he would have.  Traces of the specific nut are not enough to cause a reaction.  Once we had a full blown reaction to a cereal bar.  The response from the manufacturer was so lax I could not believe it.  So I did as I often do, I contacted the EHO and TSO.

 

More allergenic consumers should do the same, especially in restaurants.  The amount of times I've been told "I don't know if it's got nuts in it" is untrue but it all gets passed onto the EHO...  They must LOVE me!

 

For me, irrespective of the law, please understand allergenic consumers ignore alibi labelling because it is too widely used.  You may think you're going to feel ok if you killed a consumer but I can bet you that you won't. 



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Posted 25 October 2019 - 02:54 PM

Hello Team

 

We produce porridge with peanut butter.After deep clean we use 3 m clean trace for surface protein and the results came negative.But the next product which do not contain peanut which we have send for testing for peanut the results came 2.7 ppm.

 

We state on the labelling. Kitchen also handle peanuts.

 

What is the legal limit for peanut ?

 

Is there any best controls or swabs to eliminate peanut completely.

 

we are a small kitchen with just 1 line .

 

 

Thanks

 

 

Thank you all.

 

We are having SALSA audit in 2 weeks. Can i show the auditor the lab results with 2.7mg/kg.

 

THanks

 

 

Could you come one suggest the best swab kits available in UK.

 

Right now we are using 3m Cleantrace protein plus.

 

Thanks

 

 

Hi saenath,

 

Please note that, for allergens, a negative test result for proteins is a useful screening technique but (a) needs to be (allergen) validated and (b) ideally followed by some confirmatory allergen testing.  (As seemingly proven by result of yr externally tested sample). eg -

 

https://blog.neogen....should-you-use/

 

Generally, an appropriate cleaning procedure should be (ultimately) capable of yielding negative results using an allergen kit, eg -
 

After cleaning, allergens are expected to be present at <1 ppm i.e. the limit of detection of most commercial test kits. The contribution of allergen cross contamination from a cleaned surface into subsequent finished product itself is therefore likely to add a very small non-detectable risk in the finished product.

 
Specific detection methods alone give partial information about overall safety and risk, and should be used as  a  balanced  analytical  approach.  There  are  several  methods  for  specific  allergens  of  which immunological methods e.g. quantitative plate ELISA tests and qualitative lateral flow tests (LFT) in dipstick formats are the most commonly used. However, the relatively high cost is often an  impediment to their widespread adoption. Plate ELISA tests are more sensitive (typically <0.1 ppm) but require a skilled analyst.
LFTs  are  more  convenient  and  have  a  limit  of  detection  of  1  –  10  ppm  but  their  performance  can  be variable.
 

(extracted from  file below).

 

 

I googled 3 random test kits which gave peanut LODs of 1, 0.5, 5 ppm respectively.

 

I suggest to study the detailed explanations / (Campden) process examples (eg sec.4) in attached file and particularly  the (peanut) Case Study in Appendix 1.

 

Attached File  Hygiena Allergen Control and Management,White Paper,2015.pdf   687.8KB   62 downloads


Kind Regards,

 

Charles.C





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