Allergen Management Validation

Hi all,

Greeting to every one on this forum.

I have a question on annual Allergen validation. My company is a nut free environment. Though, we don't put this as a claim anywhere. It's just part of our Allergen management policy.

I am wondering if allergen validation testing on peanut is mandatory because of our policy (not claim).

Thanks,

If you are a nut and/or peanut free site then this is surely stated in your induction documents?

As for testing for peanuts, you could carry it out if your risk assessment says that you need to.  However, allergen testing is normally done after clean downs to verify the veracity of the cleaning process.

If there are any breaches of your peanut policy, you could record these as a non-conformance and undertake a root cause analysis to prevent a recurrence.  You then have evidence of taking action against breaches of the policy.

?????? testing equipment or food?

You don't have to do either if A) you're ingredients come with a CoA or CoC for peanut   and B) you spot check the lunchroom to ensure compliance and  C) you make zero label claims to be nut/peanut free

If you are a nut and/or peanut free site then this is surely stated in your induction documents?

 

As for testing for peanuts, you could carry it out if your risk assessment says that you need to.  However, allergen testing is normally done after clean downs to verify the veracity of the cleaning process.

 

If there are any breaches of your peanut policy, you could record these as a non-conformance and undertake a root cause analysis to prevent a recurrence.  You then have evidence of taking action against breaches of the policy.

Not stated in any of our documents but we have customers that are certified nut free.

Not stated in any of our documents but we have customers that are certified nut free.

I'm having a hard time understanding how your facility is "nut free" then?  You don't claim it on any of your products, don't state it on any of your documents, and don't test for it.

"Nut free" isn't just one of the 'soft' identity preserved statuses, it is something that can be objectively verified.

If your facility does not receive or process tree nuts/peanuts and you have a robust supplier/ingredient approval process re: allergen management (i.e., requiring allergen statements/questionnaires for all ingredients/materials received to ensure they do not come into contact with nuts) then I don't see why you would need to do any testing/validation as the allergen in question isn't present within your process and you do not make any "free of" claims. 

If some of your customers are certified nut free, and they use your ingredients/products, how did they come to this conclusion? If anything I would at least start a conversation with them to determine why they are using that claim when your product hasn't been claimed as nut free. Perhaps send out their product annually for allergen testing (peanuts, tree nuts) for validation.