Allergen Management do i need a risk assesment or allergen validation for a facility that produces allergen based foods only like nuts?

Hello all would like to thank you for the advice ahead.

It is my first time working for a protein bar facility and will be trying to get them SQF certified.

All our products have allergens in them since we are a nut processor, my question is will in need a full allergen management system with risk assessment or would a sanitation validation cover this since all we produce has allergen in it?

Hello and Welcome!  :welcome:

First we need to know if everything you produce has all of the same allergens in them or do you produce some things with peanuts, some with almonds, others a combination? (for example)

Thanks for the quick response.

We use almonds, cashews, pumpkin seeds, chia seeds, dates, figs and many more. These get mixed together for the finished product, so all allergens get mixed. Sorry if I'm short on my answer just started Monday and realized they haven't been in compliance for 7 months since last manager. I have segregated everything and have everything labeled so far.

EACH of your products has all of those items together? Sorry to go back to that, but if some products have almonds and cashews, and other products have fig and chia seeds, they do not have the same allergens and you will need to label accordingly. A fig is not a nut to my understanding and you can't use a blanket statement for that.

Some people are allergic to peanuts and not almonds and visa versa. 

Some people are allergic to peanuts and not almonds and visa versa. 

Agree.  Some people are also only allergic to certain tree nuts not all.  You need to consider the cross contamination risks further up the supply chain as well for other allergenic materials not brought into your plant.

Then you need to look at the risk of incorrect packaging and, if some products contain different allergens, the risks of mispacking.  I once had a public recall for the allergen not being in bold on the packaging (a requirement in UK / EU markets that it's picked out in a different way in the text.)

So yes, you need to do it.

While we might conceptually lump "tree nuts" together, a person with an allergy to one tree nut will not necessarily be allergic to another species of tree nut -- and importantly, they legally need to be labeled and handled as separate allergens.

To add.
Some European countries are starting to seperate the different nut-allergens. So you cannot claim ''contains nuts'', but you need to specify which nuts are at risk. SO instead if 14 allergens, there are now 24 to look after.

My main employer is in a factory that is completely allergen free. And I even had to validate the absence of the allergens which are most likely at risk. Honestly felt like a waste of money to me, because off course all our testing came up negative...

Same question as above:  do all of your finished goods contain the same tree nut ingredients?  If some have only almonds but others have almonds and cashews, you'll need a cleaning validation specific to the nuts.  FDA requires labeling of not just generic "tree nuts" but specifically which nuts due to the variation in the population (some suffering from tree nut allergies are only allergic to walnuts, for example).  If each of your finished goods contains all of the tree nut allergens you handle, you can probably get away with describing that in your allergen control program to justify not testing for each individual nut.  But it needs to be clearly spelled out that if you were to change formulations or introduce a new ingredient, you would ensure cross contamination is prevented within your sanitation practices.

As far as allergen handling entirely, you'll still need to maintain labeling and protocols for raw material handling.  Clients of mine in the past have tried to say they don't need to segregate allergens because their entire finished goods lineup contain the allergens, but I haven't found an auditor yet who will let that slide.

Thank you all. Jfrey i had the same idea of proving this with a sanitation validation and describing it in the program.