How do you handle allergen rework for SQF & FSMA?
How do you handle allergen reowork for SQF & FSMA? Rework is not the same as carry over correct? If I am stating "like into like " for non allergen rework would "exact into exact" for allergen rework be appropriate? For me this would me putting into the exact finished product ( we are dry blending company).
Hello!
What exactly do you mean by "carry over"?
You can always rework an allergen into its same formulation. What i do is have the supervisor and QA verify that the formulation of the product being reworked and the product that it is being reworked into are the same. It doesn't necessarily have to be the same product as long as the formula is the same.
Make sure you record all the rework that is being added to the new product for traceability purposes.
Rework and Carryover are very different.
Rework is an active decision - something being reworked is pulled from production (or production has unexpectedly stopped) but is intended to go back into production at a later time. The big risk is that it contains a known allergen, but accidentally gets reworked into a product that should be free of that allergen.
Carryover is an accident - unintentional allergenic material that gets "carried over" from one run to the next. For example if machinery isn't cleaned enough and there is still milk residue on it, and then that milk residue transfers into the next product (which would otherwise be milk-free).
To use a travel metaphor, food that's being reworked has booked an open-jaw flight -- it was supposed to go straight to its destination, but now it's taking a little time somewhere else first. Food that's being carried over is more like bedbugs waiting on the plane to jump on passengers on the next flight.
Like into like or exact into exact - the phrasing doesn't matter as much as the protocols themselves.
When we think of "carry over" we consider it the remaining product from a production run. We will "carry it over" to the next time we make the same product. For us "rework" is when we incorrectly put an ingredient in a product (ie the wrong salt) into a product and try to "rework" that into another item that uses that product.
Just establish the control measures that will be taken to ensure you don't create allergen contamination issues. E.g. a policy that says you will only rework into materials containing the same or additional allergens, and that you have a series of verification steps in place to make sure it doesn't get included in the wrong product stream (several people sign off, material stays on hold until planned use, whatever).