Allergen Management for Non-Food Safe Chemicals: Best Practices?

Hi,

Compliance around BRCGS, section 4.7.5. for FOOD GRADE lubricants/chemicals allergen status needs to be confirmed. I've read the below posts and am happy ref requirement. majority of the time suppliers have something easily accessible I can file. 

Food Grade Lubricant Allergen Free? - IFSQN

Allergen Risk Analysis for Food Grade Lubricants - IFSQN

However, if our allergen management includes prevention of banned allergens, i.e. Peanuts (peanut oil), it seems a challenge could be made to provide this information for all chemicals on site. We obviously do this for raw mat specs. 

This is a lot more work as the allergen status isn't provided outright which is frustrating (i.e on technical sheet, (M)SDS). Not sure if it has to be declared on the physical label...

Is there a way to be compliant without asking suppliers (manufacturers) for each and every material what allergens (if any) are present?

I'm also considering customer clauses/challenges not just BRC. There's nothing in BRC ver 9 explicitly stating this requirement but our allergen risk management would capture it - prohibited/undeclared allergens in a non-food safe chemical. 

Any help would be appreciated. Thanks.

hi ;)

I am afraid that this must be checked, and you should have specification in place and proof of checks. 

Don't forget about pesticide review.. I was challenged by Tesco auditor 

Thanks. I also asked an experienced auditor. Response below:

"Clause 4.7.5 is specifically intended for maintenance chemicals like oils, lubricants and greases etc.

All should have an NSF rating for incidental food contact and be supported by accompanying allergen status. Just a word of advice, the allergen status is never detailed in the MSDS sheets but comes as a separate stand-alone statement provided by the relevant supplier.

Non-Food chemicals are covered in Section 4.9 and you will have statements in the technical information sheets provided by the hygiene chemical supplier to confirm food industry status."

Yes, pesticides I've looked at :smile: . It's the niche items giving me headaches, Paint for metals, washing up liquids/dishwasher tablets from Amazon, engineering items from a local store that won't have information readily available... I even had printer cartridges on the approved list before looking at it… I can't confirm free from peanuts for things like this....  :lol2:

Plan: For the approved chemical list, I'll confirm allergen status if food grade and save evidence. Non-food grade save a technical data sheet and confirm approval. For non-food chemicals that don't have the required information, I think we'll approve through concession (can be based on risk/type of material/location). Staff are trained not to bring chemicals in the factory from outside of production. Staff are trained in allergens including site being peanut free (personal food, raw materials & chemicals). 

I think this should be compliant without me making the process over complicated which could result in nothing being followed... which was my start point.