SQF 2.4.4.2 - Allergens

Hi all,

I am getting ready for an SQF audit on a second small facility. The product is a dried potato flake but I have 2 neighbors that produce animal feed on each side of my plant, one make a soy powder feed and the other makes pellets out of many different breads, cakes ect... We have an environmental allergen testing program in house but I am wondering with the change to the code at 2.4.4.2 states

"Product analyses shall be conducted to nationally recognized methods or company requirements, or alternative methods that are validated as equivalent to the nationally recognized methods. Where internal laboratories are used to conduct input, environmental, or product analyses, sampling and testing methods shall be in accordance with the applicable requirements of ISO/IEC 17025, including annual proficiency testing for staff conducting analyses"

I am a little perplexed on how to handle this if we continue to do the testing in house if we are to do them in accordance with the ISO standards.

In my recent past audit my other plant was also doing environmental test but had not done one for a long time so we had no test results and our auditor discouraged us from do any of that in house and to use a 3rd party lab, as it opens us up to having to comply with this section of the code.

Any help would be appreciated,

William

unfortunately, SQF made this very vague.   they also ofered little guidance to auditors as to what "accordance to ...." means.   or even what is required in 17025.  

I help a friend with this section by creating a "ISO 17025" compliance procedure.    I added the general requirements of 17025 that made sense for a inhouse lab to follow including the proficiency testing portion.   (training, approved methods, calibration, etc).  the auditor had no issues with it  (they did pathogen testing and other product safety testing)  

Make sure you review the proficiency guidance document.   the link is below.   

I think you could continue to do the allergen test in house.   it is just a little more work.   Good job SQF for discouraging a company trying to do the right thing.   

Hi all,

 

I am getting ready for an SQF audit on a second small facility. The product is a dried potato flake but I have 2 neighbors that produce animal feed on each side of my plant, one make a soy powder feed and the other makes pellets out of many different breads, cakes ect... We have an environmental allergen testing program in house but I am wondering with the change to the code at 2.4.4.2 states

 

"Product analyses shall be conducted to nationally recognized methods or company requirements, or alternative methods that are validated as equivalent to the nationally recognized methods. Where internal laboratories are used to conduct input, environmental, or product analyses, sampling and testing methods shall be in accordance with the applicable requirements of ISO/IEC 17025, including annual proficiency testing for staff conducting analyses"

 

I am a little perplexed on how to handle this if we continue to do the testing in house if we are to do them in accordance with the ISO standards.

 

In my recent past audit my other plant was also doing environmental test but had not done one for a long time so we had no test results and our auditor discouraged us from do any of that in house and to use a 3rd party lab, as it opens us up to having to comply with this section of the code.

 

Any help would be appreciated,

William

Hi William,

It's complicated. And, thanks to SQF, confused.

There are several recent, extensive, discussions on this topic on this forum, eg -

https://www.ifsqn.co...cy/#entry176376

And, I think, some even more recent.

Thanks for the responses will check out the material and then decide on my course of action

You could just train and verify following the ISO standard in house

https://www.iso.org/...8593:ed-2:v1:en

In accordance = follow the procedure as described out in the link

Or you could follow the FDA procedure

https://www.fda.gov/...mental-sampling

For proficiency testing, observe and ask question annually whilst the employees are performing the swabbing, have the followed the proper procedure? and if not, did you A) reswab the area following the proper procedure and B) retrain the employee in question

SQF has lumped product testing and environmental monitoring together............seperate the two sentences in the code and that will add some clarity

Hi all,

 

I am getting ready for an SQF audit on a second small facility. The product is a dried potato flake but I have 2 neighbors that produce animal feed on each side of my plant, one make a soy powder feed and the other makes pellets out of many different breads, cakes ect... We have an environmental allergen testing program in house but I am wondering with the change to the code at 2.4.4.2 states

 

 

Any help would be appreciated,

William

Hi William,

Can you please share how you carry your environment allergen testing? We are an allergen free facility but  we have a bakery next door and we might be getting environmental allergens. I am looking into setting a program to test our air but haven't found anything useful yet.

Thanks in advance.

-Sam

Hi Sam,

Currently we are using a swab from Hygiena called allersnap I believe. It does not test for specific allergens but proteins associated with them. We swab at locations close to possible openings or places that cross contamination could occur

William

Thanks William. I used allersnap on unused equipment  that had dust settled and figured out we had environmental allergens. I guess we need to do specific protein swab now to verify it is coming from bakery next door.

-Sam