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Allergen segregation in storage

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NewQA

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Posted 08 June 2023 - 03:22 PM

Hi All,

 

As part of our allergen management system, we have to identify the allergen containing in raw material (free issue by customers) on receipt. This help to identify the allergen and avoid cross-contamination as we handle 13 allergens on site. This measure has been challenged as all the raw material is fully enclose, therefore there is not need for the use of an allergen identification.

 

Also, management has highlighted that there is not a requirement to have allergen identification in storage from BRCGS.

 

From my view, this is best practice specially to avoid cross-contamination or mix with products that does not contain allergens. however, if the information is not accurate in that identification, could end up in a NCN. 

 

Can anyone share what is your experience on control allergens on storage? 



Gelato Quality Lead

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Posted 08 June 2023 - 04:58 PM

In short, having an allergen management system with allergen separation in storage areas would be much less expensive than a potential undeclared allergen recall.

 

We are working towards SQF certification, but even for our GMP audits, we have storage areas clearly labeled and segregated for allergen-containing materials, whether they are completely sealed or not. We also identify allergens upon receipt of materials and our supplier approval program requires suppliers to have an allergen program such that we can trust that their materials will not compromise our allergen program.

 

Maybe someone with experience in BRCGS can provide information regarding their allergen control practices.



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NewQA

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Posted 08 June 2023 - 07:13 PM

We do have physical segregation for anaphylactic allergens and products that are allergen free are storage above products that contains allergens. 

 

This is a small packing company and they have never have incidents with allergens. they have challenged the fact that we use labels indicating allergens, when all products are fully enclose. Another reason they are against is because the number of new products has grown and apparently the data base is difficult to maintain.

 

I am looking for a different way to do it, but it is frustrating that they think that because is enclose, there is not risk.

 

If anyone have a allergen guideline for BRCGS that can share I will appreciated.



Charles.C

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Posted 08 June 2023 - 08:06 PM

Hi All,

 

As part of our allergen management system, we have to identify the allergen containing in raw material (free issue by customers) on receipt. This help to identify the allergen and avoid cross-contamination as we handle 13 allergens on site. This measure has been challenged as all the raw material is fully enclose, therefore there is not need for the use of an allergen identification.

 

Also, management has highlighted that there is not a requirement to have allergen identification in storage from BRCGS.

 

From my view, this is best practice specially to avoid cross-contamination or mix with products that does not contain allergens. however, if the information is not accurate in that identification, could end up in a NCN. 

 

Can anyone share what is your experience on control allergens on storage? 

Hi NewQA,

 

I suggest you acquire a copy of BRC's highly detailed Interpretation Guidelines asap. This compilation  will answer many of yr allergen queries.

Unfortunately different GFSI-recognised Standards may have varying requirements so it is often necessary to determine if differences in user opinion or implementation are relevant or not.. BRC/UK not surprisingly tends to be UK-centric.


Kind Regards,

 

Charles.C


kfromNE

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Posted 08 June 2023 - 08:28 PM

The argument that items are fully enclosed doesn't work. Ingredients break open. Forklifts hit them, they get damaged during transit, employees open them up and don't close the item properly, etc. Most likely you will toss any ingredients that become damaged. However a bag of flour damaged will spill everywhere and then potentially on a non-allergen if not segregated properly. 

 

If you are having storage issues. We will store allergens together/close by if the final production product always contains the other allergen. But this is known to us. 

For example if flour is used as an ingredient for every item you make in your plant - then cross contact isn't an issue with flour. 



GMO

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Posted 08 June 2023 - 08:37 PM

The answer with BRCGS is always, "what does your risk assessment say?"

I'm being a bit flippant but that is generally the approach.  So what is the packaging?  How do you store the items and is there evidence packaging sometimes gets damaged?  If it did, what would be the risk?  

Once you know the risk, you can start to work out what levels of control you need.





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