12 replies to this topic

[lynzy05]

Hi

 

I am having to prove why we have to clean between running Tree Nuts on the line and then Peanuts. The site manager does not want to do a full clean between tree nuts and peanuts, while the operations manager wants to do a full clean. They left me with the job to explain why we have to do it.

 

I have seen different opinions online so I am wondering, is there actually a statement that says we need to do a full clean? I am worried for the people who eat our peanuts and allergic to tree nuts.

 

Any help would be appreciated.

[Tony-C]

Hi lynzy05,

 

 

Welcome to the IFSQN forums.

 

My question would be, as per the requirements of the BRCGS standard, have you carried out validation work that demonstrates that you need to do a full clean?

 

From BRCGS Global Standard for Food Safety Issue 9 clause 5.3.8:

Equipment or area-cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination (cross-contact) by allergens. The cleaning methods shall be validated to ensure that they are effective and the effectiveness of the procedure routinely verified. Cleaning equipment used to clean allergenic materials shall either be:

• identifiable and specific for allergen use

• single use

• effectively cleaned after use.

 

Kind regards,

 

Tony

 

Edited by Tony-C, 12 June 2023 - 05:16 AM.

[lynzy05]

Hi Tony

 

Thanks for this. The site has different allergens, which includes Sesame, Soy, Gluten, Sulphites, Lupin, Dairy, Peanut and Tree Nuts. When I first started, they were validating their cleaning by testing for allergen after cleaning but they only did it for Sesame, Soy and Gluten. I am pushing for them to do a full clean from Tree Nuts to Peanuts but got a lot of push back. We will validate this by testing as well.

 

From the way they are cleaning from Tree Nuts to Peanuts, the test will be able to detect Tree Nuts after cleaning. I am understanding this as a non-conformance against the clause as this wont be removing or even reducing it.

 

Not sure if this is how should I be interpreting this.

 

 

 

Hi lynzy05,

 

 

Welcome to the IFSQN forums.

 

My question would be, as per the requirements of the BRCGS standard, have you carried out validation work that demonstrates that you need to do a full clean?

 

From BRCGS Global Standard for Food Safety Issue 9 clause 5.3.8:

Equipment or area-cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination (cross-contact) by allergens. The cleaning methods shall be validated to ensure that they are effective and the effectiveness of the procedure routinely verified. Cleaning equipment used to clean allergenic materials shall either be:

• identifiable and specific for allergen use

• single use

• effectively cleaned after use.

 

Kind regards,

 

Tony

[jfrey123]

Sounds like management here wants to mismanage the allergen risk from tree nuts to peanuts.  They are two different allergens, uniquely affecting two different groups of people.  If the products run on this line do not share the ingredients, then there is no defense for not cleaning between.  

[G M]

... They are two different allergens, uniquely affecting two different groups of people.  If the products run on this line do not share the ingredients, then there is no defense for not cleaning between.  

 

^Exactly

 

Call the procedure whatever you want, it needs to remove the allergen from the equipment that you are not including in the formulation/labeling of the second product.

[lynzy05]

They believe they dont have to do a full clean down because the finished product has a "may contain..." declaration. I am trying to use the BRC standard to make them fold and do what is right. It has been a tough road so I had to ask here...

Sounds like management here wants to mismanage the allergen risk from tree nuts to peanuts. They are two different allergens, uniquely affecting two different groups of people. If the products run on this line do not share the ingredients, then there is no defense for not cleaning between.

[G M]

They believe they dont have to do a full clean down because the finished product has a "may contain..." declaration. I am trying to use the BRC standard to make them fold and do what is right. It has been a tough road so I had to ask here...
 

 

From FSANZ

'May contain' statements

Some food labels use 'may contain' or 'may be present' statements to indicate the possible unintended presence of allergens occurring during food manufacture, such as 'may contain milk'. This is also known as precautionary allergen labelling (PAL). These are voluntary statements made by food suppliers and the Food Standards Code does not regulate them.​

 

Those statements have about as much legal standing as a lawyer crossing their fingers.  You're basically telling people that have allergies they might not want to eat your products because you don't have confidence in your own sanitation procedures.

 

The company is still 100% responsible if the allergens are in something they're not supposed to be in, regardless of how many voluntary statements you include.

[hello.fizz]

The may contains statement is also for unintentional cross contamination. If a line has not been properly cleaned it could be argued it was not unintentional and was a known.

[Tony-C]

They believe they dont have to do a full clean down because the finished product has a "may contain..." declaration. I am trying to use the BRC standard to make them fold and do what is right. It has been a tough road so I had to ask here...
 

 

Hi lynzy05,

 

I think you should show them this from BRCGS Global Standard for Food Safety Issue 9 Guidance for Clause 5.3.6:

On-pack warning labels

Where well-implemented and managed allergen management controls cannot prevent cross-contamination (cross-contact) and there is a significant and genuine risk of the presence of an allergen that would not otherwise be present and is therefore not mentioned elsewhere on the product (e.g. in the ingredients list), the use of on-pack advisory warning labels should be considered – i.e. an on-pack, advisory, consumer-facing warning label stating that there is a risk of cross-contact from an allergen, which cannot be prevented. While different wording may be used in different countries (see below), such warnings are often referred to as ‘may contain’ labels, as they refer to unpreventable cross-contact rather than to the deliberate inclusion of the allergen in the product.

The use of a warning label should be justifiable on the basis of the risk assessment and procedure (clauses 5.3.3 and 5.3.4) and should not be a substitute for effective implementation of good manufacturing practices. Reference must be made to national legislation, guidelines or codes of practice when making such a statement to ensure that best practice is followed.

 

Kind regards,

 

Tony

[lynzy05]

Thanks for this. I am compiling all my information as I have a meeting with them next week. 

 

 

Hi lynzy05,

 

I think you should show them this from BRCGS Global Standard for Food Safety Issue 9 Guidance for Clause 5.3.6:

On-pack warning labels

Where well-implemented and managed allergen management controls cannot prevent cross-contamination (cross-contact) and there is a significant and genuine risk of the presence of an allergen that would not otherwise be present and is therefore not mentioned elsewhere on the product (e.g. in the ingredients list), the use of on-pack advisory warning labels should be considered – i.e. an on-pack, advisory, consumer-facing warning label stating that there is a risk of cross-contact from an allergen, which cannot be prevented. While different wording may be used in different countries (see below), such warnings are often referred to as ‘may contain’ labels, as they refer to unpreventable cross-contact rather than to the deliberate inclusion of the allergen in the product.

The use of a warning label should be justifiable on the basis of the risk assessment and procedure (clauses 5.3.3 and 5.3.4) and should not be a substitute for effective implementation of good manufacturing practices. Reference must be made to national legislation, guidelines or codes of practice when making such a statement to ensure that best practice is followed.

 

Kind regards,

 

Tony

[oacosta60]

Your site manager needs a good training in allergens with urgency. The answer is very easy the proteins in peanut are very different to those in tree nuts. An orange and a mango are fruit, but they are very different.

 

Oscar, Ph.D.

 

[oacosta60]

Your site manager needs a good training in allergens with urgency. The answer is very easy the proteins in peanut are very different to those in tree nuts. An orange and a mango are fruit, but they are very different.

 

Oscar, Ph.D

 

[GMO]

Fundamentally peanuts and tree nuts are different allergens by law. So if you are not cleaning between, you are putting people at risk.

Unless you have a food allergy even if you’ve had training in the food industry there are so many nuances with allergy that you might not be aware of and advice from some doctors has changed in the last 20 or so years.

You can be allergic to peanuts and not to tree nuts and vice versa. But you can also be allergic to one tree nut (eg almonds) and not another (eg walnuts). It used to be that specialists would recommend avoiding all nuts if one allergy was found but the specialist we saw said differently that to avoid developing an allergy to the other nuts you should eat them.

This means that at least some allergic consumers will be eating a nut they are not allergic to when they have a different nut allergy.

Once you realise that, you realise there is no excuse not to clean between tree nut species let alone between tree nuts and peanuts!