Yes for sure, declaration has a different purpose than control program , declaration is a way of communication with the consumer before consuming the product , it is a legal issue in most countries e.g. GCC it is mandatory.
Allergen control program is a is your company's written document regarding the storage, handling, processing, packaging, and identification of allergenic foods and ingredients to mitigate the risk of cross contamination due to mishandling. if you are certified with food safety certificate it is mandatory
So they are not alternative ,
below is food code Dubai
3.6 Control of Allergens
Operational standards of the food establishment shall consider protection of consumers with food
allergies, intolerances and autoimmune diseases. Food establishments shall integrate allergen
management as a part of the food safety management system and should consider the risk from food
allergens together with other food safety risks.
3.6.1 General Requirements for Allergen Management
a. All food establishments shall implement an allergen management system.
Rationale:
The food industry faces the threat that the food it serves may endanger workers or customers. Microbes
are everywhere. Pathogenic microorganisms pose the greatest danger causing foodborne illnesses. Good
policies and procedures for preventing microbial contamination serve as barriers to these disease-causing
organisms.
58
Food Code – Version 4
b. Food establishments must declare the 12 most common ingredients known to cause allergenic
reactions when they are present in the food that is prepared or sold in the establishment.
c. The following ingredients are contained in food–whether as an ingredient, compound
ingredient, food additive or processing aid–they must be declared on the label or the menu,
no matter how small the amount:
• crustaceans and their products (e.g. prawns)
• peanuts and their products
• soybeans and their products
• tree nuts and their products (almonds, hazelnut, walnut, macademia, pecan, pistachio etc)
• sesame seeds and their products
• fish and fish products
• egg and egg products
• milk and milk products
• gluten and cereals containing gluten (wheat, rye, oats, barley and spelt)
• celery and their products
• mustard and their products
• sulphur dioxide and sulphites
d. For the product labels on packaged food produced or imported to Dubai where federal or GCC
standards are applicable, declaration of allergens can be limited to the ingredients provided in
the relevant food standards.
Note: Over 250 foods have been identified as possible allergens. While it is not possible to identify
all those foods as potential hazards, food service businesses should carryout an internal risk
assessment process as a part of their food safety management systems and identify any specific
allergens that might be applicable to a certain clientele. For instance, identification of lupin and
molluscs as allergens in a restaurant that serves to consumers from European Union where these
ingredients are labelled as allergens.
3.6.2 Management of Allergens
a. Food establishments shall conduct an assessment of raw materials to establish the presence
and likelihood of contamination by allergens listed under Section 3.6.1. This assessment
should include but not be limited to the review of raw material specifications and, where
necessary, acquire additional information from suppliers through questionnaire or supplier
59
Food Code – Version 4
audit to verify the allergen status of the raw material, its ingredients and the production
facility.
b. The establishment shall identify and list allergen-containing materials handled on site. This
list shall include all the allergen containing raw materials, intermediate, finished and newly
developed products.
c. Food establishment where a certified food safety management system is mandatory, the
establishment shall carry out a risk assessment to identify routes of allergens and establish
documented policies and procedures for handling raw materials, intermediate and finished
products to ensure cross-contact is avoided. This should include:
i. identification of the scope of the program.
ii. consideration of the physical state of the allergenic material (i.e. powder, liquid,
particulate).
iii. systematic identification of probable areas or steps of cross-contact throughout the
process flow.
iv. assessment of identified risk at each process step.
v. identification and implementation of suitable controls to reduce or eliminate the risk of
cross-contact.
vi. establish and implement systematic monitoring of those controls.
vii. establish appropriate corrective action when monitoring indicates that control is
breached.
viii. regularly review the program to ensure that the measures outlined above are working
effectively.
d. Procedures or controls implemented by the establishment to ensure the effective
management of allergenic material to prevent cross-contact into non allergen products shall
include but not be limited to:
i. physical or any other appropriate control during storage, processing and packing.
ii. the use of separate or additional protective clothing when handling allergenic materials.
iii. the use of good hygiene practices like hand washing, cleaning of food contact surfaces
etc. when handling allergenic materials.
iv. use of identified, dedicated equipment and utensils for processing
v. identify specific and labelled areas to store equipment and utensils used for processing
allergen free foods
vi. scheduling of production to reduce changes between products containing an allergen
and products not containing the allergen.
vii. systems to restrict the movement of airborne dust containing allergenic material.
viii. waste handling and spillage controls.
60
Food Code – Version 4
ix. restrictions on food brought onto site by staff, visitors, contractors and for catering
purposes.
e. Procedures shall be in place to avoid contamination during rework.
f. The establishment shall fully validate and routinely verify the production process, in case the
claim is made regarding an allergen in food.
g. Equipment or area cleaning procedures shall be designed to remove or reduce to acceptable
levels any potential cross-contamination by allergens. The cleaning methods shall be validated
to ensure they are effective, and the effectiveness of the procedure routinely verified. Cleaning
equipment used to clean allergenic materials shall either be identifiable and specific for
allergen use, single use, or effectively cleaned after use.
h. The establishment shall have appropriate internal and external communication related to
allergen management. This includes but is not limited to information related to primary and
secondary ingredients, change in procurement, recipes, packaging, preparation or production
procedures, equipment, layout and staff.
i. Establish documents and records that are appropriate for the nature and size of the food
establishment to demonstrate the effective application of the above-mentioned requirements.
3.6.3 Labelling of food with allergens
Food containing any ingredient or derived from a substance or product listed in clause 3.6.1 shall meet
the following requirements:
a. If foods containing allergen are packaged or re-packaged, the food establishment must list the
presence of these allergen with its type in the ingredient list in bold font. This shall be easily
visible, clearly legible and not obscured in any way or "Contains" followed by the name of the
food source from which the major food allergen is derived, immediately after or adjacent to
the list of ingredients, in type size that is no smaller than the type size used for the list of
ingredients
b. Modification of any recipe with an any known allergen ingredient, the food establishment shall
clearly declare on the pack with suitable warning like New recipe or Now contains, in addition
to the amended ingredients list.
3.6.4 Providing allergen information to non-packaged food
The following allergen labelling regulations apply to food sold in retail and food service
establishments.
a. When food is sold to the customers directly, for example in a restaurant or cafe, the
establishment must provide allergen information in writing. This could be either:
61
Food Code – Version 4
i. full allergen information on a menu, digital devices or boards
ii. a written notice placed in a clearly visible position explaining how customers can obtain
this information - for example by speaking to a member of staff
iii. Use allergy and intolerance icons to tell your customers how they can find out allergy
information.
b. If food is offered on a buffet, allergen information for each food item should be provided
separately. Measures should be in place to facilitate consumers with severe allergy to consume
food prior to other customers thus reducing the risk of contamination.
c. If food is sold through online platforms or provided up on phone order for a takeaway, allergen
information must be provided before the purchase of the food is completed - this could be in
writing (for example on a website, catalogue or menu) or orally (for example by phone)
d. All service staff should be formally trained on procedures and policies regarding management
of allergens prior to start of work. Service staff should:
be trained and required to ask the customer about potential allergies before
taking an order in person, or on phone
be trained on handling allergy information requests and when relevant, be able to
guarantee that allergen-free meals are served to the right customers.
e. Food handlers should know the risks of allergen cross-contact when handling and preparing
foods and how to prevent cross-contact.
f. Where the nature of the production and preparation process is such that cross-contact from
an allergen cannot be prevented, a warning shall be included on the label and/or food menu.
3.6.5 Precautionary allergen labelling
If there is a risk of a food product being affected by allergen cross-contact, the label should include
one of the following statements:
• may contain X
*
• not suitable for someone with X *
allergy
* Name of ingredient
Precautionary allergen labelling should only be used after a thorough risk assessment. It should only
be used if the risk of allergen cross-contact is real and cannot be removed.
3.6.6 Free-from Allergen Claims
Strict controls are required for ingredients, handling and preparation when foods are sold with ‘free
from’ claims. If the label or declaration in any format indicate or suggest that the product is free from
a particular allergen, this declaration has to be based on specific and rigorous controls needed to
ensure that the produce is completely free from the particular allergen. This should include verification
of ingredients and packaging materials and prevention of cross-contact.
62
Food Code – Version 4
Note: Free-from claim is a guarantee that the food is suitable for all with an allergy, intolerance or an
autoimmune disease. Exceptions for the lower limit of a particular allergen is applicable to foods when
lower limits are specified by food standards applicable in UAE
thanks,
Ehab
