Hi SHAHIDA,
Welcome to the IFSQN forums.
I don’t see this as a massive issue to you but as Patti has posted, one of my main concerns would be other allergens being present in the materials you receive from your supplier.
For the FSSC 22000 Certification Scheme Version 6 the requirements for allergen management, validation and verification are covered in 3 documents as outlined below.
Validation and verification are prescribed in International ISO Standard 22000 2018 Food safety management systems — Requirements for any organization in the food chain.
Section 8.5.3 Validation of control measure(s) and combinations of control measures
Section 8.8 Verification related to PRPs and the hazard control plan - 8.8.1 Verification
ISO 22000 isn’t particularly specific in what validation and verification is required.
Technical ISO/TS Specification 22002-1 Prerequisite programmes on food safety —
Part 1: Food manufacturing has requirements in Section 10.3 Allergen management but does not refer to validation and verification.
Section 9 Management of purchased materials 9.1 General requirements refers to verification:
Purchasing of materials which impact food safety shall be controlled to ensure that the suppliers used have the capability to meet the specified requirements. The conformance of incoming materials to specified purchase requirements shall be verified.
FSSC 22000 Certification Scheme Part 2 | Requirements for Organization to be Audited
Section 2.5.2 Product Labeling and Printed Materials (All Food Chain Categories) has requirements regarding allergens:
a) Finished products are labelled according to all applicable statutory and regulatory requirements in the country of intended sale, including allergen and customer specific requirements.
b) Where a product is unlabelled, all relevant product information shall be made available to ensure the safe use of the food by the customer or consumer.
c) Where a claim (e.g. allergen, nutritional, method of production, chain of custody, raw material status, etc.) is made on the product label or packaging, the organization shall maintain evidence of validation to support the claim and shall have verification systems in place
Section 2.5.6 Management of Allergens (All Food Chain Categories) covers allergens validation and verification:
The organization shall have a documented allergen management plan that includes:
c) Identification and implementation of control measures to reduce or eliminate the risk of
cross-contamination, based on the outcome of the risk assessment; and
d) Validation and verification of these control measures shall be implemented and maintained as documented information. Where more than one product is produced in the same production area that have different allergen profiles, verification testing shall be conducted at a frequency based on risk, e.g., surface testing, air sampling and/or product
testing;
f) All personnel shall receive training in allergen awareness and specific training on allergen control measures associated with their area of work
2.5.13 Product Design and Development (Food Chain Categories BIII, C, D, E, F, I & K)
A product design and development procedure shall be established, implemented, and maintained for new products and changes to product or manufacturing processes to ensure safe and legal products are produced. This shall include the following:
a) Evaluation of the impact of the change on the FSMS taking into account any new food safety hazards (incl. allergens) introduced and updating the hazard analysis accordingly,
So although there are requirements for validation and verification, there is only limited guidance.
As per previous posts, the important aspects to consider are:
1. Verification of your suppliers to ensure there is no risk of other allergens being present in the wheat you are purchasing. Consider if your suppliers handle other allergenic material and the potential for cross-contamination.
2. Rules for food on site such as in the canteen/rest areas and food brought to site by staff. Controls of protective clothing (such as removal of protective clothing when going for breaks) to ensure any other allergenic food consumed on site is not carried into product areas on protective clothing.
3. A simple training programme for staff to ensure they are aware of types of allergens and controls you have in place including the site rules and an emphasis on the prohibition of personal food items from product areas.
Kind regards,
Tony