9 replies to this topic

[AJL]

Hi,
So we are in a situation where we have a bakery.
We produce some gluten and some gluten free.
Some other allergens we have are egg and dairy.
Some products are.... egg and dairy free. There are also nuts handled on the site.
Can someone throw at me, all the best tips for separation and control?
We make most of the stuff by hand and have the possibility for a lot of separation of storage areas etc...what else can you think of?
Thinking we should have dedicated weighing equipment? Maybe dedicated scales etc?
Anyone had to validate scale cleaning if the same scale is used for allergens and non allergenic?
What sort of things are auditors looking for so we can show we have good allergen control?

Edited by AJL, 05 March 2022 - 07:58 PM.

[Charles.C]

Hi,
So we are in a situation where we have a bakery.
We produce some gluten and some gluten free.
Some other allergens we have are egg and dairy.
Some products are.... egg and dairy free. There are also nuts handled on the site.
Can someone throw at me, all the best tips for separation and control?
We make most of the stuff by hand and have the possibility for a lot of separation of storage areas etc...what else can you think of?
Thinking we should have dedicated weighing equipment? Maybe dedicated scales etc?
Anyone had to validate scale cleaning if the same scale is used for allergens and non allergenic?
What sort of things are auditors looking for so we can show we have good allergen control?

Hi AJL,

 

The Standard -

 

FUNDAMENTAL
The site shall have a system for the management of allergenic materials which minimises the risk of allergen contamination of products and meets legal requirements for labelling in the country of sale.

 

 

Above and following (5.3.X) Clauses sort of say it all.

 

Should obtain the BRC/I.Guidelines (if not yet possessed) which detail the interpreted response requirements.

 

BSI offer a useful introduction/examples -

 

 bsi-allergens-facility-mapping-guide_hk-1.pdf   694.2KB   80 downloads

[Kara S.]

Separation is key! To ensure you are not overlooking anything - redo your HACCP plan and ensure all of your allergens are called out. 

 

Raw Receiving

• dedicated storage locations 
• allergens are not to be stored above non-allergens (or different allergen) incase of damage and leaks

Secondary Ingredient Handling

• Color coded containers and utensils 
• dedicated tools for allergens 
• separation where you are storing any ingredients in secondary containers 
• If dust is a risk consider vent hood or dust collection systems over scales 

Product Lines

• allergen matrix of all the products you run is key to setting up a successful schedule and provides understanding of where changeover cleaning is required. 
• You can harmonize product lines (Example: dedicated gluten free line or dedicate egg to a production line) whatever makes sense per your formulations 
• Dependent on space you can add walls separating lines with allergens to those without 

Cleaning 

• Always clean after an allergen run  - you mentioned scales so that may be necessary. A change over cleaning document showing the line was visibly clean prior to starting the next run is good to have. 

 

Happy to assist with creating the program and redesign of the facility. 

[Charles.C]

The basic Key first Process question is -

 

Only one Line or ?

 

If Yes, will need to develop/apply an Allergen Change over Matrix. Discussed in detail in previous threads here.

 

PS - thread already abandoned ?

[AJL]

Thanks Kara S & Charles!
I'm working there to learn the process.
I am calling them 2 process lines, because they actually have
-dedicated storage areas
-dedicated equipment/mixing area

Plus production planning so when non allergenic products are proud, there is no other production.

[Charles.C]

Hi,
So we are in a situation where we have a bakery.
We produce some gluten and some gluten free.
Some other allergens we have are egg and dairy.
Some products are.... egg and dairy free. There are also nuts handled on the site.
Can someone throw at me, all the best tips for separation and control?
We make most of the stuff by hand and have the possibility for a lot of separation of storage areas etc...what else can you think of?
Thinking we should have dedicated weighing equipment? Maybe dedicated scales etc?
Anyone had to validate scale cleaning if the same scale is used for allergens and non allergenic?
What sort of things are auditors looking for so we can show we have good allergen control?

Hi AJL,

 

Re ^^(red) -

 

I enclose an attachment which contains, IMO, 2 impressive checklists for Allergen Risk Analysis/Control (especially see Pgs 43-54).

 

I daresay auditors may have studied the same document.

 

 Guidance-on-Food-Allergen-Management,2014.pdf   3.65MB   63 downloads

 

PS - The 1st attachment in this Post is also quite useful -

 

https://www.ifsqn.co...ss/#entry184154

[AJL]

Thanks everyone for the great comments here.
I have written an allergen management policy, a procedure for control of allergens in product development (as there is test production there), a handover document which includes what to clean and in which order, start up checks for visual check of cleanliness.
Plus re written the HACCP plan to include the allergens at each step.
Also going to validate some gluten test kits if I find time.
IMO if the surfaces are visually clean, you won't have an issue. Especially not in a product where you can make a GF free claim as long as it's under 20ppm gluten

I feel like it can often times be overlooked, that a visual control of surfaces where things can be dismantled is often more practical than swabbing, and relevant and useful validation.
Rinse waters and product testing are however great for when you have CIP process and things don't get dismantled so often.
That's my opinion, formed after reading an article from Romer labs about allergens and cleaning validations.

[Charles.C]

Thanks everyone for the great comments here.
I have written an allergen management policy, a procedure for control of allergens in product development (as there is test production a there), a handover document which includes what to clean and in which order, start up checks for visual check of cleanliness.
Plus re written the HACCP plan to include the allergena at each step.
Also going to validate some gluten test kits if I find time.
IMO if the surfaces are visually clean, you won't have an issue. Especially not in a product where you can make a GF free claim as long as it's under 20ppm gluten

I feel like it can often times be overlooked, that a visual control of surfaces where things can be dismantled is often more practical than swabbing, and relevant and useful validation.
Rinse waters and product testing are however great for when you have CIP process and things don't get dismantled so often.
That's my opinion, formed after reading an article from Romer labs about allergens and cleaning validations.

Hi AJL,

 

Re ^^^^(red) - this thread contains some support / rebuttals of your opinion plus an illustration of auditor variabilities -

 

https://www.ifsqn.co...an/#entry145644

 

Should be an interesting project to validate that any pair of eyes can differentiate between, say, 4ppm and 6 ppm of any allergen when the requirement is, for example, < 5 ppm

 

PS - I hope you noticed this current thread -

 

https://www.ifsqn.co...th/#entry184706

[AJL]

Thanks Charles! Much appreciated. Yes tickled pink to be chosen, what an honor. But I must say I received a lot more advice than I gave :)

Thanks for sharing link, it was good reading. We are really lucky to have a team with a really good understanding and respect for allergens.
The processes they had already implemented when I started surpass my expectations!
But it would be great of course to have a scientific validation of the process, and the quick swabs for verification.
We usually take the first product produced after a run with gluten as our validation, and this has been (thus far) accepted by auditors. Having said this, it seems like all auditors have a different approach when it comes to validations around allergens, some will want to see that the cleaning process itself has been validated when there is shared equipment..

Edited by AJL, 14 April 2022 - 09:07 PM.

[Charles.C]

Thanks Charles! Much appreciated. Yes tickled pink to be chosen, what an honor. But I must say I received a lot more advice than I gave :)

Thanks for sharing link, it was good reading. We are really lucky to have a team with a really good understanding and respect for allergens.
The processes they had already implemented when I started surpass my expectations!
But it would be great of course to have a scientific validation of the process, and the quick swabs for verification.
We usually take the first product produced after a run with gluten as our validation, and this has been (thus far) accepted by auditors. Having said this, it seems like all auditors have a different approach when it comes to validations around allergens, some will want to see that the cleaning process itself has been validated when there is shared equipment..

Hi AJL,

 

Yes, the "Process" route is a commonly used and accepted approach but obviously has one potential limitation - wastage if not immediately successful.

 

Some auditors seem to consider this step  must be included within the overall Validation Procedure, others not so much.