allergens as Hazard
I have not searched the forum yet,
but I have a question: In ISO 22000 or FSSC 22000, is it required to identify allergens as a hazard, include them in the hazard analysis, conduct a hazard assessment, and then classify them as OPRP or CCP?
I work in a Catering and warehousing
Is there a way not to treat allergens as a hazard and instead simply inform all my customers that my materials may contain any type of allergen?
NO
allergens MUST be treated as a chemical hazard
your lack of good GMP's is not your customers fault
Allergens are specifically called out as a class of common hazards in most jurisdictions regulations. Do the food safety regulatory bodies where you plan to serve these foods recognize allergens as hazards?
Agree with Scampi.
It's never appropriate to just say "buyer beware" just as it wouldn't be for any other hazard.
As to whether you split them out from other chemical hazards? That tends to be the British approach to allergen hazards but most other countries have them as a subset of chemical hazards.
It is entirely possible that catering can cause food deaths due to allergens. Multiple cases of it have occurred across the world. Even warehousing which may seem low risk has had its issues.
Do the work. Give a crap about your consumers.
Allergens are specifically called out as a class of common hazards in most jurisdictions regulations. Do the food safety regulatory bodies where you plan to serve these foods recognize allergens as hazards?
Allergens are specifically called out as a class of common hazards in most jurisdictions regulations. Do the food safety regulatory bodies where you plan to serve these foods recognize allergens as hazards?
NI
In my country,
there are no testing methods for allergens and no clear procedures for storing allergenic materials.
When referring to British references or the Codex, all they say is "separate allergens, do not store them on top of each other." There are not enough references that clearly explain this subject.
Another question: Can the application of PRPs be sufficient to control allergens?
I will explain further.
From my point of view, when the allergenic material is tightly sealed, what is the issue with storing it together with other materials? Why must I place it in a designated area? If I were to allocate a specific place for each allergenic material, I would need a very large storage space.
If PRPs are sufficient that's still considering it in your HACCP plan, just stating you have PRPs in place to control the hazard.
If you're only talking about warehousing, which isn't clear as you wrote catering earlier as well, but sticking to warehousing, yes spillage from one material to another does happen. It happens because damage occurs with forklift movements. That can contaminate the exterior of packaging of an ingredient underneath. Therefore it's good practice to not store allergens above non allergens or primary packaging. Additionally if you have picking or access to pick from the warehouse, I've known of a box of an ingredient being returned or placed on the wrong pallet leading to a recall.
It's all possible, it's all controllable via PRPs but that still means it's a hazard that needs control. PRPs do not mean you don't record it in your HACCP plan.
And this is why we should have a professional designation......................................
Scampi, how's shrimp business?
HAHAHA I'm not actually in the shrimpin business that was the name of my fav cat
Dear IFSQN members,
I have not searched the forum yet,
but I have a question: In ISO 22000 or FSSC 22000, is it required to identify allergens as a hazard, include them in the hazard analysis, conduct a hazard assessment, and then classify them as OPRP or CCP?
I work in a Catering and warehousing
Is there a way not to treat allergens as a hazard and instead simply inform all my customers that my materials may contain any type of allergen?
Hi!
I would certainly do a deep dive here on allergens. There are many topics that could be helpful.
Are you shipping what you are catering out of your country? Here is a very helpful site with a list of each country’s allergens. https://farrp.unl.edu/IRChart/
I do not see anything listed for Jordan. You can get a sense of how varied and detailed allergens from other countries are.
People who have allergies to food ingredients risk complications from stomach upset to serious anaphylactic shock. The latter is why it is so important to detail what allergens you have in your facility.
I hope this is helpful as you begin this journey.
Good Luck!
Hi suhaibalbadawi97,
You will need to obtain a copy of all the relevant standards to go through this process. You need to establish the prescribed Prerequisite Programmes in the first place before you can move on to hazard analysis as explained below.
To clarify from ISO 22000 Terms & Definitions food safety hazards include allergens:
3.22 food safety hazard
biological, chemical or physical agent in food (3.18) with the potential to cause an adverse health effect
Note 2 to entry: Food safety hazards include allergens and radiological substances.
With regards to compliance with ISO 22000, in the first place you need to comply with PRP requirements:
ISO 22000 8.2 Prerequisite programmes (PRPs)
8.2.1 The organization shall establish, implement, maintain and update PRP(s) to facilitate the prevention and/or reduction of contaminants (including food safety hazards) in the products, product processing and working environment.
8.2.3 When selecting and/or establishing PRP(s), the organization shall ensure that applicable statutory, regulatory and mutually agreed customer requirements are identified. The organization should consider:
a) the applicable part of the ISO/TS 22002 series;
b) applicable standards, codes of practice and guidelines.
8.2.4 When establishing PRP(s) the organization shall consider:
List a) construction …. to l) others, as appropriate
8.5.1.5.3 Description of processes and process environment
….
c) existing PRPs, process parameters, control measures (if any) and/or the strictness with which they are applied, or procedures that can influence food safety;
You then move on to hazard analysis whilst considering the effectiveness of the prescribed PRPs which I have quoted below.
ISO 22002-100:2025 is intended to be used when establishing, implementing and maintaining the PRPs specific to the organization(s) in conjunction with ISO 22000:2018, 8.2.
ISO 22002-100:2025 Part 100: Prerequisite programmes on food safety —Requirements for the food, feed and packaging supply chain Section 12 Measures for prevention of contamination:
Systems shall be in place to detect, prevent, control or minimize contamination and cross-contamination, to an acceptable level relevant to food safety hazard assessment. Contaminants can include allergens, physical, chemical or biological agents.
NOTE Contamination prevention activities can be highly sector specific. In recognition of this, the different sectors have identified key aspects which are applicable to their specific activities. These can be found in the sector- specific parts of the ISO 22002 series.
For Specific PRPS for Warehouse we refer to ISO 22002-5:2025 Prerequisite programmes on food safety — Part 5: Transport and storage
Allergen Control is NOT in the requirements of ISO 22002-5:2025 so you will need to determine what risks there are in the warehouse operation typical examples include control of open products and control of spillages.
For Specific PRPS for Catering we refer to ISO 22002-2:2025 Prerequisite programmes on food safety — Part 2: Catering Section 12 Measures for prevention of contamination
12.2 Allergen Control. Here there are extra specified requirements:
Products shall be protected from unintended allergen cross-contact, as applicable, by:
a) cleaning;
b) segregation;
c) additional protective clothing;
d) use of dedicated tools/equipment.
NOTE Allergen cross-contact can arise from either:
……
There are other requirements to make relevant allergen information available to the consumer, address allergen control in meal preparations and specific training in allergen awareness.
For those working with FSSC 22000, FSSC 22000 Version 6 Additional Requirements apply:
2.5.6 MANAGEMENT OF ALLERGENS (ALL FOOD CHAIN CATEGORIES)
The organization shall have a documented allergen management plan that includes:
a) A list of all the allergens handled on site, including in raw materials and finished products;
b) Risk assessment covering all potential sources of allergen cross-contamination;
c) Identification and implementation of control measures to reduce or eliminate the risk of
cross-contamination, based on the outcome of the risk assessment; and
d) Validation and verification of these control measures shall be implemented and maintained as documented information. ………………
Note there are further requirements e) to h)
Kind regards,
Tony