What does present in same facility mean?

I have only a limited number of allergens in my facility. However, I originally thought that since my lunchroom is in the same building as my Ingredient Storage and Processing I would have to list that "All Allergens" (Big 9) are present in the same facility. Is this true? I have an Allergen Management Program and have been SQF Certified for a number of years. Is there something I am missing?

Are you storing actual ingredients with allergens?

Or are you asking if you need to state all the big 9 as there is no control on what staff brings in and consumes for lunch?

I store and use ingredients that contain milk, wheat, tree nuts, etc. Obviously the allergens that are brought in for lunch may contain any possible allergen but as they can be present in the same facility, is this what this line is for? Or does that classification refer to an allergen that is present in that same general area but will not be processed on the same equipment?

I am no expert in those kind of claims personally.  I have been in a plant for awhile now that does not store or use any allergens.  I thought such lines as 'may contain' and 'are present in same facility' were frowned upon in the industry.  Not to say they can't be or people still don't use them, just always thought it was just generally frowned upon.

Having said that I would interpret the 'present in the same facility' to mean you are storing these allergens in your facility.  If it would say 'manufactured on the same lines', I would interpret that the allergens are being manufactured in your facility.  Again, I am not an expert on these lines at all, just how I would interpret them.  I would think there is some sort of reference out there that spells this out though.

I have only a limited number of allergens in my facility. However, I originally thought that since my lunchroom is in the same building as my Ingredient Storage and Processing I would have to list that "All Allergens" (Big 9) are present in the same facility. Is this true? I have an Allergen Management Program and have been SQF Certified for a number of years. Is there something I am missing?

We do the same as Setanta, and we are under BRCGS.

KTD

Disallow consumables generally, or specifically allergens, to be taken into your production area with a general GMP personnel policy -- and take reasonable steps to enforce it.  That will preclude the need for the kind of generic warning statement you're asking about.

When you see those "processed on equipment that also contacts XYZ" kind of statements it just means they aren't trying or can't achieve a level of sanitation that would prevent allergenic cross contamination.  It's a bit disturbing that the FDA still allows this.  

From a UK perspective a few  Retailers cop (M&S in particular) have a requirement that any site not handling Nuts and Sesame as raw materials must also ban from all areas including staff areas and canteens.

"Present in same facility" means allergens you don't use on the particular line. For instance, for a product, containing MILK & EGG, you checkmark milk and egg "YES" in  all 3 column "Present in product", "Present on the same line", and "Present in the same facility". Then other allergens (used in other products) should be indicated "NO" in 1st column "Present in product" and "YES" in 2nd and 3rd columns. 

"Present in same facility" means allergens you don't use on the particular line. For instance, for a product, containing MILK & EGG, you checkmark milk and egg "YES" in  all 3 column "Present in product", "Present on the same line", and "Present in the same facility". Then other allergens (used in other products) should be indicated "NO" in 1st column "Present in product" and "YES" in 2nd and 3rd columns. 

Hi olenazh,

Re ^^^^ (blue) -

Could also be NO/NO/YES or NO/(UNINTENTIONALLY) YES/YES.

Re^^^(red) -

Including the Lunchroom in same building ??

I anticipate the text Objective relates to existence of potential for cross-contamination, presumably (?) including unintentional.

I have only a limited number of allergens in my facility. However, I originally thought that since my lunchroom is in the same building as my Ingredient Storage and Processing I would have to list that "All Allergens" (Big 9) are present in the same facility. Is this true? I have an Allergen Management Program and have been SQF Certified for a number of years. Is there something I am missing?

Hi mehurst,

Is this a SQF-related query ? - I was unable to find any textually related requirement in SQF 9 Food or Packaging ?

(Lunchrooms are handled in 2.8.1.1 ii)

Since you posted in the SQF section, I'm not sure what requirement you are trying to meet.  "Present in the same facility" is not in the standard that I can find.  

As Charles stated you do have to assess breakrooms, etc.   "An assessment of workplace-related food allergens that may originate from locker rooms, vending machines, lunchrooms, and visitors"

I HAVE seen auditors question items from vending machines not being listed.   We had a typical - this / these raw materials contain X allergen, and these finished produced contain x allergen.   Yet a peanut product was not listed and was in the vending machine.   

I think as long as you address the potential of what you allow employees to bring in and your methods of reducing the risk, etc, you should be fine.   

I never include our lunch room as a potential source of UNINTENTIONAL allergens as our workers are trained not to bring any food or drink to the production areas, plus any other hygiene training. Otherwise, those unintentional allergens would be anything, just simply anything. No, I don't agree with Charles.

We ditched our break room vending machines due to auditor push back on the peanuts in the candy bars...   Probably could have argued it with training and GMP's, but not the hill I felt like dying on, so ditched um.

Hi mehurst1361,

The requirement is to conduct an assessment to determine if there are any potential allergen hazards in these areas which require control to prevent sources of allergens from contaminating product:

2.8.1 Allergen Management (Mandatory)

2.8.1.1 …. The allergen management program shall include:

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

Most site have restrictions in place and procedures that prevent any allergens that may be present in lunchrooms from contaminating product including limiting food to the lunchroom, removing protective clothing and hand washing.

Where sites are declaring a product as allergen free, it is not unusual to ban that allergen from all areas on site, including lunchrooms, to minimise the potential risk (however small) of contamination.

Kind regards,

Tony

I never include our lunch room as a potential source of UNINTENTIONAL allergens as our workers are trained not to bring any food or drink to the production areas, plus any other hygiene training. Otherwise, those unintentional allergens would be anything, just simply anything.

I second this almost entirely, only to add that I have in the past referenced my lunchrooms on my allergen programs as potential sources of the Big 8 (now 9 Major, in FDA's language), and list the PRP's we have in place to reduce the threat.  I have zero interest in telling my employees they can't bring a sandwich with mayo and cheese for their lunch, and I have zero interest in enforcing disciplinary action upon our workers who are just trying to eat meals their budgets allow for.  Not to mention that in the documentation rich SQF scheme, having to create some sort of periodic verification that employees aren't bringing prohibited items into the lunch room just seems like a recipe for headaches and a full blown revolt.  "You there, prove to me that bread doesn't contain wheat or egg or I'm putting you on notice!"

In one plant, we had a vending machine owned and operated by someone independently, and the lady filled it with all the regular goodies you'd expect from a machine.  I had customer and SQF auditors question it, so I noted that we don't select or provide the snacks inside, and employees could easily pick any similar snack item from home and bring it themselves, therefore the vending machine isn't "adding" any extra risk.  I always welcomed the discussions, and after referencing our program, auditors never found any fault in the program as I had written it.

Hi olenazh,

 

Re ^^^^ (blue) -

Could also be NO/NO/YES or NO/(UNINTENTIONALLY) YES/YES.

 

Re^^^(red) -

Including the Lunchroom in same building ??

 

I anticipate the text Objective relates to existence of potential for cross-contamination, presumably (?) including unintentional.

Hi Olena,

My Post was maybe unclear. "Blue" comments were  independent of "Red".

The "UNINTENTIONAL" was a hypothesised option if maybe only one line using all products with maybe dissimilar allergens, etc, etc. Actual situation unfortunately unknown.