Risk assesment for nut allergen to remove it from the system
Hello All,
The site i work for has had a no nut policy for several years now. I am unsure why this policy was brought in, in the first place. But this policy strictly enforces that our staff cannot bring in nuts or any products containing nuts.
Currently at least 60% of our staff are from south east asian countries and nuts are a big part of their diet. It is getting very difficult to keep up with our own policy. I do not have any documentation as to why this policy was incorporated in the system initially.
I want to remove it from the system but it involves doing a thorough risk assessment but i cannot find any article that may help me change this policy.
I understand that nuts are allergens and staff are provided sufficient options to prevent cross contamination such as a blue over coat for staff while consuming their lunch, if their unforms are soiled they must change it before entering into the food production facility.
What do i do and how do I go about this?
It may be related to what your product is and whether or not it is intended for people with Nut allergies like a sunflower seed butter or something like gummy bears that are generally considered safe.
You can try swabbing a few employees when they come in the plant before washing and gowning. If any of them test positive, then check them again after the gowning process. Or randomly check employees for allergens on their hands and PPE to see if the current no nut policy is even effective.
I watched this video recently. It shows a support dog indicating that there is peanut residue on the outside of a bag of bread. It's more likely that another shopper touched the bag with contaminated hands than a bakery employee.
Video is from Detective Harley, F.A.D.D.
It was probably put in place by someone who found it easier to ban than give the issue a good look over
Are you saying they PUT ON CLOTHES for lunch???
If your employees don/doff a uniform at breaks and lunch and wash hands prior to touching said uniform, you could add that to the risk assessment and be done with it
I'm with Scampi: cite your controls that lunches/snacks are only permitted in the breakroom, smocks/uniforms for the floor are prohibited in the breakroom, handwashing is required prior to donning smocks in the production/storage areas, and severe penalties for your basic GMP of no food/snacks to be brought out into the production area. I think just about any risk matrix would let you show that basic pre-reqs here reduce the risk to insignificant measures.
I have zero interest in policing my employee's lunch items. I can't imagine having to discipline an employee because I saw them eating a Snickers bar outside on their break. I can't imagine having to create a checklist to inspect employee lunch boxes for 'contraband' items. Nope. Not doing it. Fight me Mr. Auditor, employee lunches are their own business.
Beyond that, banning nuts opens an auditor to ask, "why only a nut prohibition in the employee lunches?" It looks like Australia recognizes the same major food allergens as the USA, so if nut contamination from your employee lunches is a concern, why isn't wheat or milk? Shellfish can cause Anaphylactic shock to the at-risk individuals, and my experience marrying into an Asian family tells me shrimp is also a big part of their diet, so again why prohibit nuts while not prohibiting shellfish?
In some very low risk facilities where cross contact from clothing is difficult, e.g. beverages, it's still the norm for people to wear clothing into rest rooms etc. I don't like it and don't agree with it because even in beverage processing there is still a manufacturing element somewhere.
If you were going to get rid of the nut ban, which I actually strangely enough DO agree with and I'll explain later, then I think you need to sort out your workwear issue. Unless there is ZERO chance of any of your workwear contaminating the product flow or packaging a consumer touches, why the hell are you allowing staff to wear workwear in a canteen? Why is the control to put clothing on not take it off? That's bonkers. It's just so much harder to control someone putting on a coat and making sure it's sufficiently covering workwear than the other way round. Then there's the fact they'll be wearing their hygienic workwear in the toilet as well.
But if you have controls like 90% of food factories in the world where coats are removed BEFORE breaks, then I'd think differently. Nut bans came into lots of factories at a time when allergen controls were pretty weak in most sites and if we're honest, allergen training was too. There is no more risk to an allergenic consumer of a member of staff eating nuts on break than a consumer allergic to sesame when they're eating a sesame seed covered bap. If anything, the risk on the second case is worse as seeds falling off is highly likely. So you could then validate it by doing allergen swabs on someone's hands and workwear after they ate something nut containing for lunch if you wanted to be really rigorous. But to be honest, I've worked in factories audited by GFSI which both do and don't have nut bans and both have been fine.
My ONE caveat to that though is that nuts are loose and easy to create an alarmist contamination incident with. One site I worked in did have a nut ban and the day of BRC we found peanuts not just in one place in the car park but everywhere. We got it cleaned up before the auditor (it was in the announced days) but as a result we did do some bag checks. The fact nuts were banned meant that had we found some (we didn't) we could have disciplined just for possession. So that would have been kind of helpful.