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Is an Allergen Program a must for non-allergenic production?

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#1 BostonCream

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Posted 05 November 2019 - 07:51 PM

Hi all, 

 

We are honey packer that brings in raw honey, then filter, pasteurize and pack into retail packages. It's a single ingredient product, and we don't have any kinda allergens in ingredient or lubricant oils. The only allergen source is from employee kitchen. 

 

Here's what we did:

- A risk assessment showing "satisfactory"

- "No uniforms in lunchroom" policy

- Annual employee allergen training

- Employee/contractor/visitor GMP policy

 

In this case, do we still need a specific "ALLERGEN CONTROL PROGRAM" that summarizes all above, or can we just PROVE to the auditor that we did address the allergen awareness?

 

We are under SQF and Costco. Both standards put allergen control program as a mandatory.



#2 The Food Scientist

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Posted 05 November 2019 - 08:15 PM

 Allergen control program that addresses the above. 


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


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#3 mahantesh.micro

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Posted 06 November 2019 - 04:30 AM

Hi,

Agree with The Food Scientist,  its better to have allergen control program and describe what all precautions that you are going to take to avoid allergen contamination, along with actions to be taken in case allergen cross contamination occurs.



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#4 Charles.C

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Posted 06 November 2019 - 05:03 AM

Hi all, 

 

We are honey packer that brings in raw honey, then filter, pasteurize and pack into retail packages. It's a single ingredient product, and we don't have any kinda allergens in ingredient or lubricant oils. The only allergen source is from employee kitchen. 

 

Here's what we did:

- A risk assessment showing "satisfactory"

- "No uniforms in lunchroom" policy

- Annual employee allergen training

- Employee/contractor/visitor GMP policy

 

In this case, do we still need a specific "ALLERGEN CONTROL PROGRAM" that summarizes all above, or can we just PROVE to the auditor that we did address the allergen awareness?

 

We are under SQF and Costco. Both standards put allergen control program as a mandatory.

 

So YES. There are SOP documentation examples on this forum.


Kind Regards,

 

Charles.C


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#5 Aliali

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Posted 06 November 2019 - 07:56 AM

I see the need of an allergen management plan in an non-allergenic production environment because the plan needs to document how the company ensures all the ingredients are free of allergen during the product development stage. 



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#6 zanorias

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Posted 06 November 2019 - 10:23 AM

Potential for contamination will always exist - considering and controlling the hazards will still apply, such as those listed above (+ supplier). The policy itself will be key in proving to the auditor that you've made the relevant considerations and have controls in place.



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#7 Rose Karuma

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Posted 06 November 2019 - 11:13 AM

in deed an allergens control plan is inevitable for a successful food safety management system. That said, you need to consider the fact that an untrustworthy or a disgruntled employee might sabotage your product with allergens along your product flow. 



#8 TimG

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Posted 06 November 2019 - 06:37 PM

in deed an allergens control plan is inevitable for a successful food safety management system. That said, you need to consider the fact that an untrustworthy or a disgruntled employee might sabotage your product with allergens along your product flow. 

It was my impression, and I may be wrong, that this type of sabotage would be handled solely in your Food Defense Plan, not in your allergen control program. The AGP would only handle allergens which could possibly impact product during course of normal business (which could include employee lunch, residue on uniforms, etc. for facilities that have no allergens in process).



#9 Tony-C

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Posted 07 November 2019 - 03:13 AM

Hi Yiyi,
 
The SQF Code is still quite clear that you need to document your controls and have an 'allergen management program':
2.8.1.1 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:
ii. An assessment of workplace-related food allergens from locker rooms, vending machines, lunch rooms, visitors
2.8.1.11 Sites that do not handle allergenic materials or produce allergenic products shall document, implement and maintain an allergen management program addressing at a minimum the mitigation of introducing unintended allergens through suppliers, contract manufacturers, employees and visitor activities.
 
Kind regards,
 
Tony






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