8 replies to this topic

[adolph morando]

We have been an allergen free manufacturing company up until the change with adding sesame to the allergen list.  Anyone got an allergen policy y they can share.

 

[MDaleDDF]

Much depends on what you make, do you make anything else without sesame, etc. It's not a blanket thing, depends.... 

Can you share a little more information about your operation?

[OrRedFood]

Good morning - Yes, a little more info would be helpful, such as are you under FSMA? We are under FSMA plus have our HACCP plan, which adds a bit of extra documentation but not too much. 

 

Our areas of concern are allergen labeling (presence on labels when received), Ingredient receiving. segregated storage of ingredient(s), cross contact during batching and cooking, order of production, proper labels on proper products, and validation of our sanitation procedures for removal of allergens. 

[adolph morando]

We make a line of 8 blended seasonings.  Half of the line is sea salt combined with fresh herbs and spices and the other half are basically blended spices and some seeds. Sesame seed is the only allergen ingredient and it is used in only one of the 8 blends.  The same blending and filling equipment is currently used for all products - no segregation.  We could segregate equipment for the filling line and possibly the mixing also,  if that would make compliance easier.  Also, we could make the 1 product that contains the allergen on segregated days of production.  For this one product there are is no a additional processing steps- just blend and fill.

[adolph morando]

Good morning - Yes, a little more info would be helpful, such as are you under FSMA? We are under FSMA plus have our HACCP plan, which adds a bit of extra documentation but not too much. 

 

Our areas of concern are allergen labeling (presence on labels when received), Ingredient receiving. segregated storage of ingredient(s), cross contact during batching and cooking, order of production, proper labels on proper products, and validation of our sanitation procedures for removal of allergens. 

 

Yes we come under FSMA and same for the HACCP plan.

[Sayed M Naim Khalid]

I don't know exactly what is your company doing. But if you are working in manufacturing, you may want to follow the following points: 

1. allergen labeling (you may need to print new labels for all your products that contain sesame) 

2. allergen cross contamination and how to reduce/avoid them

3. allergen spill clean up (may need different training)

4. allergen poster (informing employees on the risk of allergens)

5. environmental testing for allergen free (especially if you have one line for multiple products)

6. Finally, training on allergens, risk of allergen and how manage the above areas 

[OrRedFood]

Dedicated equipment is the best way to go if you have that option. Evaluate your air systems to make sure allergens in the air do not contaminate your allergen free equipment.   If no dedicated equipment, then separate production day with a sanitation program that is validated to remove sesame allergen is necessary.  

 

Validating that your sanitation program is effective at removing all traces of allergen from all lines and equipment before producing a non-allergen product is not difficult -   Hygenia is a great resource - they sell allergen swabs, and also provide free training of how to swab and technical advice on how to best use their swabs/allergen testing kits. 

 

Do you already have a HACCP and a FSMA plan with a flow chart in place? If you are using common equipment, you need to take your HACCP flow chart and walk the line physically with the Food Safety Team and look at your CCPs for HACCP and PCs for FMSA and add allergen controls to both plans.  Be sure to add labeling as a CCP/PC as mislabeled allergenic product is the #1 reason for recall in the USA. 

 

100% agree with above comment as well.  

[Scotty_SQF]

What scheme are you audited to?  That should help by looking at that section of the code and starting from there to create your allergen program.  Other factors that come into play: Is sesame in only one product you manufacture or all products?  Will this be on shared equipment?  How will you clean between?  How will you validate cleaning?  What steps will you take in terms of accidental cross-contamination? etc.

[Tony-C]

What scheme are you audited to?  That should help by looking at that section of the code and starting from there to create your allergen program.  Other factors that come into play: Is sesame in only one product you manufacture or all products?  Will this be on shared equipment?  How will you clean between?  How will you validate cleaning?  What steps will you take in terms of accidental cross-contamination? etc.

 

Topic is in SQF Food Scotty so I would assume it SQF

 

We have been an allergen free manufacturing company up until the change with adding sesame to the allergen list.  Anyone got an allergen policy y they can share.

 

Hi Adolph,

 

I presume that you are talking about the new legislation: Allergic to Sesame? Food Labels Now Must List Sesame as an Allergen

https://www.fda.gov/...sesame-allergen

 

Are your products currently labelled allergen free?

 

Your policy will depend on whether you current handle sesame on site and have sesame in your products.

 

If it is another allergen to exclude from site because none of the products contain any allergens, then SQF Code 2.8.1.11 applies:

Sites that do not handle allergenic materials or produce allergenic products shall document, implement and maintain an allergen management program addressing at a minimum the mitigation of introduced or unintended allergens through supplier, contract manufacturer, site personnel, and visitor activities.

 

If sesame is handled on site you will need to comply with the SQF Food Safety Code: Food Manufacturing – System Elements Section 2.8.1 Allergen Management (Mandatory) and your policy should be based around that.

 

Kind regards,

 

Tony