2 replies to this topic

[lavalienteQA]

Hello all, 

Need clarification on this section for the SQF Code for Food Manufacturing-

I ask questions within the code so as to receive advice and/or clarifcation.

 I am dependent on our hazard analysis in our FSP- and wondering if I satisfy the code. Our facility recently passed our audit in November without the assessment.. 

 

2.8 Allergen Management 

2.8.1 Allergen Management  (Mandatory)

2.8.1.1 "The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented. The allergen management program shall include:

i. A risk analysis of those raw materials, ingredients, and processing aids, including food grade lubricants, that contain food allergens;

Hazard Analysis currently holds risk analysis for all- including allergens. 

ii. An assessment of workplace-related food allergens that may originate from locker rooms, vending machines, lunchrooms, and visitors;

Does this mean to utilize a risk assessment quantitve template of some form? I.E   Low-High Risk? if so, is there a standard template or scoring card?

iii. A list of allergens that is applicable in the country of manufacture and the country(ies) of destination, if known;

iv. A list of allergens that is accessible to relevant staff;

Allergen training is conducted and protocols are in place throughout the plant including color coding that alerts staff of allergens present. Is an actual list posted somewhere necessary?

v. The control of hazards associated with allergens and incorporated into the food safety plan, and

vi. Management plans for control of the identified allergens."

2.8.1.2 Instructions shall be provided to all relevant staff involved in the receipt or handling of raw materials, work-in-progress, rework, or finished product on how to identify, handle, store, and segregate raw materials and products containing allergens.

2.8.1.3 Provisions shall be made to clearly identify and segregate foods that contain allergens. Segregation procedures shall be implemented and continually monitored.

2.8.1.4 "Where allergenic material may be intentionally or unintentionally present cleaning and sanitation of product contact surfaces between line changeovers shall be effective, appropriate to the risk and legal requirements, and sufficient to remove all potential target allergens from product contact surfaces, including aerosols as appropriate, to prevent cross-contact.

Separate handling and production equipment shall be provided, where satisfactory line hygiene and clean-up or segregation are not possible."

2.8.1.5 Based on risk assessment, procedures for validation and verification of the effectiveness of the cleaning and sanitation of areas and equipment in which allergens are used shall be documented and effectively implemented.

2.8.1.6 Where allergenic material may be present, product changeover procedures shall be documented and implemented to eliminate the risk of cross-contact.

2.8.1.7 The product identification system (refer to 2.6.1.1) shall make provision for clear identification and labeling, in accordance with the regulatory requirements of those products produced on production lines and equipment on which foods containing allergens are manufactured.

2.8.1.8 The product trace system (refer to 2.6.2) shall take into consideration the conditions under which allergen-containing foods are manufactured and ensure full traceback of all ingredients and processing aids used.

2.8.1.9 The site shall document and implement methods to control the accuracy of finished product labels (or consumer information where applicable) and assure work-in progress and finished product are true to label with regard to allergens. Measures may include label approvals at receipt, label reconciliations during production, destruction of obsolete labels, verification of labels on finished product as appropriate, and product change over procedures.

 

Edited by lavalienteQA, 15 June 2022 - 09:30 PM.

[Tony-C]

Hi lavalienteQA,

 

SQF Guidance, Tip Sheets and Checklists does offer some help here:

 

TIP SHEET 17 ALLERGEN MANAGEMENT

 

2.8.1.1.ii. The allergen management plan shall include an assessment of

workplace-related food allergens from locker rooms, vending machines, lunch rooms, visitors.

1. Irrespective of the site’s considered allergen exposure, a risk analysis is required of all ingredients, materials, the workplace (canteens, locker rooms, vending machines) to determine the risk of cross-contact allergens so that action can be taken to minimize or eliminate the risk.

 

2.8.1.1.iv The allergen management program shall include a list of allergens which is accessible by relevant staff

1. A list of everything within the site that contains allergens that can be accessed by the staff involved in production operations shall be outlined. Staff awareness is critical to avoiding unintentional inclusion of trace amounts of allergenic material in products, and training must be provided that includes the consequences of unintentional consumption of allergens and the methods required to prevent contamination. Trace amounts of allergenic materials can be transferred to products from clothes, incorrect ingredient selection, spillages, and inadequate cleaning.

 

Although the SQF Food Safety Code has Allergen Management in System Elements there is some guidance for Risk Assessments in Pre-requisite Programs

 

The site should have a prescribed process for completing and documenting a risk assessment. The following 3 step process is recommended:

1. Identification of hazards at any location or process step. Similar to how a hazard analysis is completed within the food safety plan the site should consider any biological, chemical or physical hazards that could occur and importantly what can cause them. Using descriptions from preventive control methodology hazards that are reasonably likely to occur in the absence of controls should be considered.

2. Evaluate each hazard and how it might occur to determine if there are any controls that are being applied or can be applied to eliminate or reduce the hazard to acceptable levels. This evaluate is crucial so that risk can be assessed in the next step.

3. Estimate the risk of the hazards using a likelihood vs severity assessment or similar type of tool. The definitions for each level of likelihood and severity will be important so that it can be consistently applied. A measurement tool should be applied so that the output can definitively indicate risk level and thereby any appropriate control.

 

I tend to use a simple 3 x 3 risk assessment template, here is an extract from the Allergen Control System included in IFSQN packages.

 

 FS 2.8 Allergen Control System.jpg   193.21KB   2 downloads

 

Also note, in reaching a judgment on the risks involved with a particular allergen you need to consider a number of factors including the following:

 

-           the amount of the allergenic food generally needed to provoke a reaction in a sensitive individual

-           how common adverse reactions are to that particular food in the population to which it will be marketed

-           whether there are particular subgroups of the population likely to be at particular risk, such as babies and young children

-           the relative allergenicity of the particular ingredient being used. For example, possible cross-contamination with refined nut oils which are highly processed ingredients, is likely to pose a lower risk than cross-contamination with either whole, or pieces of, nut.

-           the physical nature of the particular ingredients being used and the geography of the manufacturing environment. The physical form of the allergen is important, for example a liquid and a powder represent different types of risk. Milk powder may represent a greater risk in situations where air-borne contamination of products is possible, but liquid milk may be of less concern if there was sufficient separation.

 

Kind regards,

Tony

[Scotty_SQF]

SQF is big with phrases like risk assessment.  I would suggest doing a phrase search for risk assessment and everywhere it comes up, make sure you do a risk assessment for it as auditors will ask.  I would keep the assessment for lunches, vending machines, etc. simple.  A simple risk vs. severity will work.  I would also have a list for your records as well for what allergens are accessible to staff.  I believe they are using that to tie into/link to how likely could it be that someone can access the allergen easily and maybe added into something you are making that does not have that allergen...Food Defense.  I have been noticing they are starting to make connections to the different programs, which makes sense as all programs should support and supplement each other when possible.