It would be worth them reaching out to RSSL. They will give some great "official" advice on this.
Of course there is nothing stopping a manufacturing site from assigning additional materials as allergens if they are seen as allergens of concern by the market they are supplying.
BUT what it's important to remember is you don't have to test for every allergen when validating or verifying cleaning programmes. What causes most allergen issues in consumers isn't a trace amount left after cleaning, it's wrong packaging, wrong recipe or wrong ingredient. That doesn't mean that it's not worth validating the cleaning efficacy of some equipment but it does mean that you should do a bit of a mindset shift on what you're trying to achieve. The point of allergen validation is to check that the method is capable of removing allergenic residues.
So once you've designed your cleaning process, you then choose which allergen to test for. That choice is going to be governed by several things:
- Cleanability of the allergen off the surface (milk and egg are often the most difficult)
- Concentration of the allergen in the recipe
- How many recipes you use with that allergen in
- Level of allergen sensitivity in the population
- Availability of tests
- Sensitivity of tests
So for each you're going to want to choose the MOST difficult to clean, highest concentration, most susceptible population risk and the best most sensitive, most available tests.
To re-emphasise the point that doesn't mean testing every allergen in all of your formulations!
So for example, say your site processes milk and that's 50% of one formulation, milk is present in 20 recipes and lychee is 10% of one recipe only formulation, I would only test the milk.
Then once validation is achieved, you can choose what your ongoing verification and monitoring is. That can be as simple as visual inspection, it does not have to include rapid swabs.
