BRCGS P617 Position Statement Allergen Management

Hi all, I have been looking at the recent publication P617 from the BRCgs. for Packaging. What concerns me is that we  have always considered allergens. By that I mean performed HACCP on the 14 regulated food allergen, but now this position statement is talking about Latex and fragrances. It talks about bin liners with scent. I struggle to see this  relevant to food packaging. I guess that is going to be the conclusion from my Risk Assessment. I just wondered what anyone else though of this PS617 and if you think I have missed the point and could point me in the right direction.

Thank you

Is your operation food packaging process or manufacturing of packaging material?

My understanding for this PS617 is that the allergen risk must be taken into consideration on packaging materials.

Since single-use material is being banned, the development and production of new types likely go in 2 directions (AFAIK):

- high recyclability 

- quick (bio)degradability or compostability. 

The second case mostly requires bioengineering and/or bio-materials which introduce allergens. Hence, the PS617, IMO, helps to raise the allergen awareness of industrial application from R&D stages, in the entire process for material producers and in supplied materials for packing & packaging operators.

Hi Beautophile,

Thanks for your reply.

In answer to your question, we make packaging.

We buy sheets of food grade cartonboard, print, cut, fold & glue into cartons and sleeves for food. Some times it is direct contact with the food but mostly it is not. I have previously checked with the suppliers (board, Ink, glue,) about the 14 food allergens but now it looks like I need to go back and ask about Latex. 

Hello there! 

My take on this position statement is that BRC is wanting certified sites to assess the risks of potential allergens related to materials used in the process rather than potential cross-contamination from employees, their clothing, or their foodstuffs. All previous discussions around allergens with the auditors I've had have been centered around our employees somehow tainting product with allergens. This position statement says that the assessment 'shall include raw materials as virgin and recycled formats, intermediate and finished products, processing chemicals, inks, solvents, and traded products.' This points straight to raw/intermediate materials, finished product, and processing aids. For the vast majority of us, it will be an assessment listing all these items with no significant hazards to note.

Hi nwells1024,

thanks for that. Yes I thinks that is a good point and it does appear to be  a new take on the focus but what concerns me is that in the PS617  they talk of STARCH & LATEX , both of which are not food allergens.  I think starch is not an allergen at all as it is a sugar not a protein. I don't want to ask my suppliers about these as they will say they are not relevant to the regulations on allergens. The PS also talks about perfume which is surely not relevant if food packaging. Bin liners are not food packaging they are waste receptacles. I think the PS goes off in the wrong direction after focusing on raw materials and process.