Can we be allergen free but still have allergenic ingredients worked on in the R and D area?
R&D constantly brings in allergenic ingredients to their department, even though we are considered an allergen free facility. Obviously I wouldn't allow it, if it was my decision but it keeps happening. I have an allergen policy that states we are allergen free. Is there a way to still be allergen free but still have allergenic ingredients worked on in the R&D area?
The side-line potential for contamination of allergen introduction from R&D is very great.
Your facility is not allergen free.
Do you also keep the lunchroom allergen free?
Just trying to gauge the companies understanding
@SQFconsultant I know. I am in my own boat over here.
@ Scampi Yes, we keep the lunch room allergen free. I understand well, but like I said, I am in my own boat over here. :helpplease:
My facility does not make any allergen-free claims, however, R&D does sometimes handle allergens that are outside the scope of our typical allergens. I have special R&D procedures built into my allergen program to control for this. I gave R&D allergens their own allergen-specific color designation, they have their own dedicated equipment, and their own dedicated storage areas. R&D employees undergo the same food safety training as production employees, with a special emphasis in ensuring that R&D does not contaminate production.
Honestly, I wouldn't consider your facility allergen free, nor should you demand it. It really is unreasonable from an employee point of view. In fact, today in my lunch I brought in milk, wheat, tree nuts (two kinds), and eggs from my lunch. The other point is how do you verify and ensure employees are following the policy? Do you audit their food and lunches?
If your products are allergen free why does R&D keep obtaining ingredients with allergens? That would be my first question to R&D.
You would be better served by implementing control procedures to ensure allergens do not enter your production, storage, or process areas. Can you isolate all R&D activities to a laboratory or confined room?
There is always a risk for contamination in your facility, like your lunch room for instance. So I believe you cannot be 100% allergen free.
You will need to come up with an allergen plan on how to prevent cross contamination from the R&D into your facility.
R&D constantly brings in allergenic ingredients to their department, even though we are considered an allergen free facility. Obviously I wouldn't allow it, if it was my decision but it keeps happening. I have an allergen policy that states we are allergen free. Is there a way to still be allergen free but still have allergenic ingredients worked on in the R&D area?
Couldn't you change it to allergen free in production areas and coolers. We do this for glass. R & D has a shelf in the production cooler and not allowed to store glass on it. Only in the R & D test kitchen.
R&D constantly brings in allergenic ingredients to their department, even though we are considered an allergen free facility. Obviously I wouldn't allow it, if it was my decision but it keeps happening. I have an allergen policy that states we are allergen free. Is there a way to still be allergen free but still have allergenic ingredients worked on in the R&D area?
It's easy. Issue a Company Policy which defines "allergen-free".
This is what Policies are for. :smile:
Do you also keep the lunchroom allergen free?
Just trying to gauge the companies understanding
Uhoh, I have an allergen free statement that states our product has no allergens. Put it together a few years ago.
Our facility has no allergens (chem review, ingredient review, etc.) but the GMP of handwashing is our allergen control program for the lunchroom. Maybe I need to update this document to and remove 'allergen free'?