How to come up with an EMP Program for an Allergen Free Facility?

Hi everyone: 

 

Can anyone here help me to come up with an EMP program by incorporating Allergen Verification. Please take note that our facility is an allergen free. 

During our stage 1 audit the auditor have raised that our existing EMP program does not include the verification of allergen. 

Is it necessary to have a swab testing? or will it suffice the process of requiring personnel to do hand washing, etc? 

 

Hope anyone can help me with my concern. 

 

Thank you 

Yes, you need testing - not necessarily swabs -  you can test final product too.

Also, very few companies consider the risk of cross-contamination of agro products while growing in the field.

I've also seen American companies who sell to Europe utterly ignore the European list of allergens claiming to be allergen free while having celery and other allergens present. If you want to sell internationally, test for all the legal allergens in your target countries.

You might also want to sign up for the Food Safety Friday webinar about allergen management in food production on March 14, 2023 elsewhere on the IFSQN website.

Hi SHQuality, 

 

A sample product can be sent through lab testing at least once a year to verify the claims of allergen free product. While PRP controls should be consider to prevent cross contact. 

 

Thank you 

 

Yes, you need testing - not necessarily swabs -  you can test final product too.

Also, very few companies consider the risk of cross-contamination of agro products while growing in the field.

I've also seen American companies who sell to Europe utterly ignore the European list of allergens claiming to be allergen free while having celery and other allergens present. If you want to sell internationally, test for all the legal allergens in your target countries.

What PRP do you suggest to control the risk of cross-contamination on the field of cultivation X steps back in the supply chain when you have zero control over it?

In my opinion, you should at least insist on allergen testing results from your suppliers.

Hi everyone: 

 

Can anyone here help me to come up with an EMP program by incorporating Allergen Verification. Please take note that our facility is an allergen free. 

During our stage 1 audit the auditor have raised that our existing EMP program does not include the verification of allergen. 

Is it necessary to have a swab testing? or will it suffice the process of requiring personnel to do hand washing, etc? 

 

Hope anyone can help me with my concern. 

 

Thank you 

Hii...

 

Yupp... I think at least you have a validation document that proves your facility is free from the allergen

Can someone please move this threat to the appropriate forum?

Hi everyone: 

 

Can anyone here help me to come up with an EMP program by incorporating Allergen Verification. Please take note that our facility is an allergen free. 

During our stage 1 audit the auditor have raised that our existing EMP program does not include the verification of allergen. 

Is it necessary to have a swab testing? or will it suffice the process of requiring personnel to do hand washing, etc? 

 

Hope anyone can help me with my concern. 

 

Thank you 

 

Hi norielsoriano,

 

Just noticed this thread.

Any particular Standard involved ? eg BRC, SQF etc ?

To be clear and EMP has nothing to do with allergen cross contamination (at least under SQF) and everything to do with pathogens

Environmental Monitoring A risk-based environmental monitoring program shall be in place for all food manufacturing processes and immediate surrounding areas, which impact manufacturing processes.
The responsibility and methods for the environmental monitoring program shall be documented and implemented. An environmental sampling and testing schedule shall be prepared. It shall at a minimum:
i. Detail the applicable pathogens or indicator organisms to test for in that industry;
ii. List the number of samples to be taken and the frequency of sampling;
iii. Outline the locations in which samples are to be taken and the rotation of locations as needed; and
iv. Describe the methods to handle elevated or undesirable results.

Environmental testing results shall be monitored, tracked, and trended, and preventative actions (refer to 2.5.3.1) shall be implemented where unsatisfactory results or trends are observed.

 

 

 

What your talking about is VALIDATIONS of your allergen free facility

 

A simpler way to control allergens in your facility is to get COA with every shipment of ingredients and/or a statement from the manufacturer about how they control allergen introduction at their facilities

 

If your swabbing in house, it would be because you believe that allergens are being introduced somewhere along your supply/process chain, that should be controlled using other methods

 

Allergen swabbing is usually done to ensure no cross contamination in facility that do process some products with an allergen(s) and some without

 

 

Hi Scampi,

 

Allergens are mentioned in some EMPG packages but, as you noted, afai can see, BRC, SQF only mention microbial issues, eg pathogens, indicators, spoilage organisms.

Maybe different Standard or the auditor self-extended due the "allergen free" environment(?) claim.

More like the auditor not understanding what a validation is!  (she says partially tongue in cheek)

 

 

The allergen free claim still needs to be monitored via a allergen program which really has zero to do with an EMP

 

I would push back on the EMP request--but would encourage proper and timely validations