6 replies to this topic

[MDaleDDF]

We're a dry blending facility, FSSC 22k certified.   We have wheat, milk, egg, and soy in the building, and I'm working on a product that is gluten free/vegan.  

 

It's still in the R&D stage in the lab at the moment, but it's going well, so I'm starting to consider impacts of production.  Any and all tips about validation, verification, etc, are things I'm curious about.  So any input you lovely food professionals out there have would be appreciated.

We used to do a parve run back in the day, and I don't honestly see it being much different than that.   We'll shut down for a day and clean production top to bottom via SOP's, I'll swab to ensure it's clean, run GF/V product, and send it out for gluten testing before releasing it for sale.  I already have a Work Instruction for allergen free parve production, so I'll just add the GF/V into that paperwork.

Am I missing anything?

Thanks, yall rock, as always.

[SQFconsultant]

Are you going for a side certification for Gluten Free?

[Tony-C]

Hi MDaleDDF,

 

Sounds like a plan.

 

I presume that your cleaning validation will include Gluten swabbing/tests e.g. Gluten Protein Rapid Kit

 

Also, that the product samples that you send out for gluten testing before releasing for sale will include a ‘first off’ sample?

 

Kind regards,

 

Tony

 

[jfrey123]

Is this product being made for the retail consumer, or as a blending facility are you producing something for commercial use down the chain?  I ask only because I think you should look hard at your customer base to decide if GF and Vegan certifications are going to be worth the effort.  For the Vegan crowd, I have a perception that their team will not embrace your Vegan product knowing it was made in a facility that uses animal products.  GF is a difficult cert to go for as you have to guarantee all ingredients from all vendors are gluten-free or tracked properly through your system, and that actually means more than chasing wheat as an ingredient.

 

I just say review whether a Vegan or GF cert is worth it.  If your customers are commercial use and would accept a letter detailing your allergen controls, the certs won't necessarily help.

 

As for processing, I'd work hard to re-test your current sanitation methods and ensure they are eliminating the allergen residues.  I mean, in theory, you should have some robust validation of your current sanitation that it is controlling the allergens you run.  Then I'd update production to account for sequence running the non-allergen product prior to your older normal products.

[SQFconsultant]

Jfrey123 said in part:

 

"For the Vegan crowd, I have a perception that their team will not embrace your Vegan product knowing it was made in a facility that uses animal products.  GF is a difficult cert to go for as you have to guarantee all ingredients from all vendors are gluten-free or tracked properly through your system, and that actually means more than chasing wheat as an ingredient."

 

===================

 

I agree, and will add that Vegetarians (like me) and Vegans would become not only extremely agitated that animal products are processed in the same facility but Vegans will go to great lengths to damage the target company by spreading the word - having seen companies having to handle damage control, it's not a pretty sight.

 

We had a bakery in Brooklyn, NY as an SQF client and they called one day and asked if we provided consulting on Gluten-Free (at the time we were listed as consultants for a Gluten-Free Certification (I think it finally became a part of BRC) and they said they wanted to jump on the money-train (as they called it) in Gluten-Free by offering GF products and wanted me to come in and tell them what they needed to do - they did not want to have a separate facility to produce GF (which is what I thought they wanted to do), they wanted to produce smack in the middle of their bakery and I knew there was no way that was going to happen.

 

But, anyway, I took a ride over to them and we did a feasibiltiy study and it was determined it was a no-go as far in the plant - so we consulted building a separatwe building - you know that thing about not going over 20 points of gluten makes people think it's a "lot of leeway" but it is extremely tight, many folks focus on that number and end of exceeding it - me thinks it is better to focus on 10 so that it never even gets near 20.

 

It's also amazing the amount of secondary sources of gluten in a facility - wheat is used in so many things from lubricants, to glue. 

 

Case in point we had a Gluten Free company that kept on exceeding the counts for finished product - working in reverse we found a bead of glue that held the buffer disk under a cap was the culprit.

 

Lots of things to think about and track in this arena.

[MDaleDDF]

Firstly thank you all for the awesome input!   You guys rock.

 

So:

 

- I have no interest in a GF certification until mandatory, no.

 

- Everything that Tony stated:   Yes.   And I intend to send every batch out for a GF test and won't release it until it passes.   Also going to do a full scale pilot run, and toss the batch no matter what.   And thank you Tony for the link to some swabs, because what kind to use was definitely a question I had.   I'll give those a look.

 

- My current sanitation and swabbing/path protocol is extremely robust, and overdone according to all past auditors, which I prefer to lacking, so I'm not worried about that at all.  I'm lucky enough to have an old school sanitation crew that really kicks butt, and our path system has been working perfectly for 15 years.   Not that I'm not open to updating it as needed, I am, but I think it's rock solid at the moment.

 

- The product will not be retail, sold to a large chain, and through distribution.   We're all dry ingredients, so I have like dried eggs, milk, etc, but that's it.  There's no cow carcasses hanging from the ceilings or anything, though I understand the vegan folks would still not want to consume that.    I'm not worried about kickback from the vegan community about me having these in the building, they won't know where it's manufactured anyway.   And I don't think I'm pulling the wool over anyone's eyes, as long as I'm doing my due diligence and I'm sure the product is 100% clean of animal products, and 20 ppm GF, etc. 

 

- The plan will be to shut down for Thursday and clean all day first and second shift till it's spotless, swab, run Friday (ONLY this product), send product for testing, release after a clean test.  We'll do another clean second shift Friday night and Saturday for normal Monday production.

We have in the past as I stated done allergen free runs, and it went good, so I'm not TERRIBLY worried about the process, but I certainly respect it and feel like I'm pretty much familiar with what I need to do here.   But I'm definitely wanting to slow walk it and make sure it's all done right.

 

Thanks again you guys, much appreciated.   Keep the thoughts coming if you have more!

Edited by MDaleDDF, 15 August 2024 - 02:14 PM.

[emportllc]

At the risk of saying something obvious — make sure you confirm that whichever swabs or product tests you use in-house WILL in fact pick up the allergen if present (otherwise the negative swabs aren’t worth a whole lot). 

 

If you’re already doing a lot of swabbing with other swabs (I assume ATP), it’s worth setting up your initial validation to explore how much you can trust those data points to indicate allergen cleanliness. 

 

General protein swabs may or may not be helpful— like ATP they can be a day-to-day verification tool that lets you collect more data points for the same price. Not to replace allergen-specific swabs, but to supplement. It may be worth running some during your initial validation, alongside the rest, so that if you want to work them in down the line they are validated and ready to go.

 

Since you’re working with dry materials — if you are getting unexpected positives, look at airflow. Both on the production floor AND in the lab / wherever you run the tests. I could tell you stories ...

 

There are a number of different lines of rapid tests for allergen-specific surface swabbing as well as ingredient and product testing. Whichever line you go with, check the instructions or validation data before you purchase to make sure there aren’t cross-reactivities that would be issues for you.