20 replies to this topic

[Simon]

Allergen Management

Start Time: Tuesday, December 14.  2:00 PM London, 9:00 AM New York

Amanda Evans-Lara, Food Safety Compliance Specialist, HACCP Mentor

 

Ask Me Anything discussion session on Allergen Management.

 

[HACCP Mentor]

I am looking forward to taking your questions about allergen management in Food Safety Live 2021!

 

[HACCP Mentor]

Thanks for all of the questions asked during my AMA session at Food Safety Live 2021. If I was not able to answer your question during the allocated time, please feel free to ask in this forum. If you are looking to learn more about food allergens and putting together your allergen management programs, please check out my Ultimate Guide to Allergen Management at: https://haccpmentor....gen-management/

[HACCP Mentor]

Could you please post the link to the website that you mentioned that could be be used to determine the possible allergens in food?

 

Check out https://haccpmentor....known-allergens. You can see the link as Unexpected Allergens in Food

[HACCP Mentor]

Amanda , You mentioned a references to guidance documents from Codex . Please can you give titles and links?

 

Hi Francis. You can find it at: https://www.fao.org/...%2FCXC_080e.pdf

[HACCP Mentor]

How can you validate that soybean oil doesn't have the allergen present?

 

Validation: The supplier would advise to you that the raw material does not contain allergens.

Verification: You have the raw material tested to see if it contains your particular allergen of concern.

[HACCP Mentor]

Talking about the big 8 allergens, which can be fatal if consumed and which ones are not?

 

All allergens have the potential to be fatal if consumed. It really does depend on the allergic consumer. Peanut and nuts have been associated with death. If you complete a google search you can find plenty of case examples of fatalities related to the consumption of food containing allergens.

[HACCP Mentor]

What is the best allergen test kit for fish? I am employed to a meat plant and fish plant? 

Do cleaning chemicals and laundry detergents/chemicals normally have allergens? 

(1) Best ask your local laboratory as there are different test kits for different types of fish.

(2) Both have known to contain allergens. For any that you are using, best to contact the supplier and also refer to the material specification sheet.

[HACCP Mentor]

In case you declare that your products "may contain" for example 10 allergens, due to circumstances of your process, which are the minimum requirements that must be presented during an audit to evidence that "you did the expected"?

 

 

I am not sure that I completely understand your question Marcia   The use of 'may contain' statements on product labels should always be validated using an acceptable methodology. You may like to check out the VITAL Program which is a risk-based tool to assess the impact of allergen cross contact to provide appropriate precautionary allergen labelling. You an see more at: https://vital.allergenbureau.net/

 

If I was auditing your facility and completed a label review, I would expect to see sound, relevant justifications as to what 'may contain' allergen statements you have made on label.  When I see unvalidated claims it tells me as an auditor that your cleaning processes are not effective in preventing cross-contact allergens.

[HACCP Mentor]

Hi Amanda

 

Thank you answering some of my questions. This Q/A was very useful. I have a few others if you don't mind

 

1. in your opinion do you think visual labels such as allergen placards are necessary if allergens are segregated systematically?

2. Could randomly swabbing personnel/employees/secondary packaging be a form of risk assessment or could this possibly create more issues if a result comes out to be positive?

3. Does allergen in finished product packaging need to be segrgeated by type of allergen? How about raw material? Do they need to be segregated by type of allergen?

 

We don't have ay GFSI recognized certificate but we have AIB which seems to be mostly focused on IPM, Sanitation and Facility maintenance and PM

 

Thank you so much

 

(1) Yes - allergens should always be clearly labelled. It helps to avoid cross-contact or ingredient misuse.

 

(2) What you mention is more verification rather than risk assessment. Risk assessment assesses the potential risks involved in a nominated activity. Your results of verification (e.g. the swabbing you mention) could be used (absent of any other data) as the starting point for assessing 'likelihood' of the particular allergen being present.

 

Doing the type of swabbing that you mention can give insights into the effectiveness of cleaning and presence of your target allergen.

 

(3) Raw materials, ingredients, WIP and finished products should be clearly labelled with their allergen status. Segrating storage helps to prevent allergen cross-contact.

[HACCP Mentor]

Here the link to an International Regulatory Chart for food allergen labelling regulations. https://farrp.unl.edu/IRChart

 

It is a great resource to see what allergens are declarable by law in what countries.