Introducing a New Allergen in a BRCGS-Certified Cheese Facility
Hello Folks,
I need assistance in introducing a new allergen in a BRCGS-certified plant.
My facility is a cheese company, and currently, milk is the only allergen present. Management has asked for my opinion on purchasing vegan cheese from a supplier and only handling the cutting and packaging of the product in our facility.
I would like to understand the potential for cross-contamination if we proceed with buying this new product and performing only the cutting process.
The name of the cheese and ingredient list is as follows:
I'd be more concerned about how the Vegan community is going to think when they find out that there favorite cheese is cut in a plant that primarily processes dairy.
Our family eats this cheese and the thought of it being in a facility that does regular dairy is concerning.
So, I'd be telling management - NO.
What are the risks of bringing that product into our plant?
Could you please help me with that details so that i can tell my management no to take the product?
Is there any allergen in the product?
If the vegan cheese is allergen free, you could also suggest sequencing to control allergen risk: starting the day/shift with processing the vegan cheese and transitioning to the dairy allergen later after a wash between.
How do the sequencing to control allergen risk?
Coconut (oil).
Coconut is considered a tree nut per the FDA so would be an allergen that needed to be declared if you are selling it in the United States.
It is not considered an allergen in Canada.
Hi, having worked in cheese, I'd have some reservations about this.
As rightly said above, there is a bizarre law in the US which identifies coconut as an allergen (other countries don't, it's a drupe not a nut). So there is the risk in that direction for US consumers but probably worth checking if any coconut protein is there anyway in the oil (normally it's highly refined).
To me the bigger risk is cross contact from your normal production of milk onto your vegan products. I'm not sure about Canadian law but UK law does permit vegan to not be "milk free", i.e. you can put a "processed on a machine which also processes milk" statement on pack or "may contain milk", but it's seen as (and is) SUCH bad practice. People with milk or fish allergies actively seek out vegan food assuming it to be safe. So to my mind while vegan isn't actually a "free from" claim, it kinda is because consumers assume that to be the case.
Using the same equipment for free from and contains is not a complete no-no but it's VERY difficult. This is where my normal aversion to rapid swabbing would go right out of the window and I would be buying up Neogen's stock of rapid casein swabs... Not because I think they're fabulous but because you have then got more due diligence. You would need super robust and robustly validated (using ELISA) cleaning processes which remove all traces and you'd also need to think about how you'd control people etc. I wouldn't want you packing normal cheese and vegan cheese at the same time if you can avoid it to prevent someone walking across lines. Lastly one of the biggest risks isn't in the cross contact at all but the wrong packaging. As soon as you bring that vegan packaging on site, you then introduce a risk of accidentally packing your normal product in that. Unless you have good line controls with pack scanning on every pack, it would be a no from me. And never, never forget how much training you will have to do...
If you're struggling to convince your leadership about this, cost out the steps, time and money needed for proper control of this and put the plan in front of them. They may be surprised how much it would take to control and surprised enough about the cost and effort they may not realise it will wipe out the potential profit from the packing operation.
I have a podcast I LOVE called "cautionary tales", it's a British guy who presents but it's aimed at the American market mainly. But in one episode he talked about the difference between "unintended consequences" and "unforeseen consequences". Don't let your leadership get away without foreseeing that there are potential consequences here even if they're not intended and the more you rely on behaviours to control them, the higher the risk of the unintended consequence (even if you have a great food safety culture.)
Coconut is considered a tree nut per the FDA so would be an allergen that needed to be declared if you are selling it in the United States.
It is not considered an allergen in Canada.
FDA finally got on board with botanists and decided coconut isn't a tree nut anymore.
New guidance came out earlier this month.