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aphro

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Posted 17 May 2007 - 08:24 AM

Hi everybody,

According to ISO 22000 req, while conducting hazard analysis we should considered allergens ( if any ). We had already searched for references about the sources and the type of allergens, but never found clear references on HOW TO CONTROL THOSE RESPECTIVE TYPE OF ALLERGENS, for example : by heat treatment etc.

Can anybody help? thanks in advance

Regards
Aphro



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Posted 17 May 2007 - 09:02 PM

hi everybody,

according to ISO 22000 req, while conducting hazard analysis we should considered allergens ( if any ).
we had alreday search references about the sources and the type of allergens, but never found clear references HOW TO CONTROL THOSE RESPECTIVE TYPE OF ALLERGENS, for example : by heat treatment or etc... etc....

does anybody can help us ?? thanks in advance

regards
Aphro

Allergens anyone? :smile:

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Charles.C

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Posted 18 May 2007 - 11:25 AM

Dear Aphro,

A few ideas from a US perspective.
“Written programs are the primary means by which food manufacturers address allergen-control issues. The main goals of an allergen-control program are to ensure that product labels accurately describe a food's ingredients; and to prevent cross contact between allergen-containing products and allergen-free products or between products containing different allergens.
........
In USDA-FSIS-inspected establishments, allergen-control programs are typically regarded as prerequisite programs but establishments may choose to address allergen control in their HACCP (hazard analysis critical control points) plans. If the prerequisite program approach is used, facility personnel must also determine whether "undeclared allergens" should be listed as a potential chemical hazard in the ingredient-receiving step of the hazard analysis.”
http://www.foodsafet...h...2004/10&p=8

There is an impressive survey of manufacturing approaches to addressing allergen concerns here -

http://www.blackwell...37.2006.00012.x
(large file)

Rgds / Charles.C


Kind Regards,

 

Charles.C


YongYM

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Posted 19 May 2007 - 05:48 AM

Have a look on this link.

http://www.mda.state...fgallergens.htm



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Posted 21 May 2007 - 03:25 PM

Dear Aphro,

A few ideas from a US perspective.
“Written programs are the primary means by which food manufacturers address allergen-control issues. The main goals of an allergen-control program are to ensure that product labels accurately describe a food's ingredients; and to prevent cross contact between allergen-containing products and allergen-free products or between products containing different allergens.
........
In USDA-FSIS-inspected establishments, allergen-control programs are typically regarded as prerequisite programs but establishments may choose to address allergen control in their HACCP (hazard analysis critical control points) plans. If the prerequisite program approach is used, facility personnel must also determine whether "undeclared allergens" should be listed as a potential chemical hazard in the ingredient-receiving step of the hazard analysis.”

Rgds / Charles.C



Hi Charles,

as I read the allergen problem, I'm wondering if allergenes are considered a PRP or oPRP? Considering the many measures you have to take (identify ingredients, check supplier allergen-control-programm, special allergen sanitation procedure) I would say it's a PRP. Do you agree?

Thanks for helping!

Regards,
Agleh


Charles.C

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Posted 21 May 2007 - 06:10 PM

Dear Agleh,

As you say and as illustrated in YongYM’s nice link, there are a wide variety of possible control measures involved.
It seems to me that depending on yr specific risk situation and the degree of application specificity which exists (or can be created?), it is possible to end up with PRP’s, oPRPs and CCPs.
(If you wish to see an example of possible CCPs, can try these (Non-I22K) links –
http://www.cfsan.fda...mm/haccp4s.html
or
http://www.inspectio...kbrpou10e.shtml )

Nonetheless, I would be happy to be proven wrong so as to end up with a simpler result! :whistle:

Rgds / Charles.C


Kind Regards,

 

Charles.C


aphro

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Posted 24 May 2007 - 11:44 PM

dear charles,

so it's means allergens can not be reduced or even eliminated, it's only can be prevented, isn't right ?

aphro



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Posted 25 May 2007 - 05:00 AM

Dear Aphro,

If you mean something like – ‘ where handling a food with a known allergenic component, is there a general processing treatment (eg heating) to prevent, eliminate or reduce the hazard to an acceptable level ?' then the answer for all the common cases seems to be simply No (hence all the prevention measures requiring labeling, avoiding cross-contamination etc)

For example see this extract (2006) -

"3.2.1 General Principles
Allergens should be managed to avoid their unintentional presence in products wherever possible. This management involves evaluation of the likelihood of allergen cross-contamination associated with every step of the food production process, from sourcing raw materials through to marketing of a finished product.
Food businesses generally already have Good Manufacturing Practice (GMP) in place. These require a commitment and discipline to ensure products meet food safety, quality and legal requirements, using appropriate manufacturing operations, including effective food safety systems (using hazard analysis principles) and quality assurance systems. Existing GMP controls will assist with allergen management, for example avoiding cross-contamination by segregation, cleaning, using separate utensils etc. However, it should be noted that unlike microbiological risks, heating does not necessarily destroy food allergens and may actually increase their potency, for example roasting peanuts."
( http://www.food.gov....ontainguide.pdf )

(Nonetheless I noted there are apparently some exceptions, eg cooking certain fruits - http://www.eatwell.g...ergicreactions/ )


As to whether a cross-contamination hazard requires labeling, an authoritative answer seems to require some further expert knowledge / risk assessment / regulatory factors etc. One risk assessment procedure is given on Pg 28 of first reference and in the following reference also (2005) which contains a HACCP analysis and a helpful IMO Decision Tree (see Appendix3)
http://www.food.gov....lguidance05.pdf

Hope this helps to answer yr query. Seems to me that this is a currently very highly studied area (and recalls) so any more comments welcome.

Rgds / Charles.C


Kind Regards,

 

Charles.C


aphro

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Posted 08 June 2007 - 04:20 AM

thanks Charles, all these guidance was very helpfull to decide wether we obliged to labelled "may contain" on our product

the next question is :

1. in the hazard analysis, how should we put the severity level for allergen ( high, medium or low ?), according to this guidance and it is very common that different people can have different level of sensitivity and that sensitivity can vary in the same person under different circumstance

2. as my understanding : the risk level ( likelihood) can be decided according to the effectiveness of our allergen management programme or procedure, please correct me if I am wrong

regards
Aphro



Suzuki

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Posted 08 June 2007 - 07:58 AM

Dear Aphro

While it is required under the standard to perform a hazard risk assessment, you cannot possibly have allergens controlled under your hazard plan because it cannot be eliminated, removed or reduced to an acceptable level.

Since allegence is due very much to reaction of proteins and you have clearly noted that sensitivity differs from persons to persons, the only approach to dealing with allergens under any food safety programs is really through "Good Label Management" on all possible allergens that may have an impact on your sensitive consumers.

Afraid the onus is on the Manufacturer to ensure the relevant allergenic ingredients are clearly spelled out. You may also want to consider in certain cases "This product is produced from equipment that may contain ......"

Regards
Suzuki



Charles.C

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Posted 08 June 2007 - 10:53 AM

Dear Aphro,

As Suzuki said, the current situation is rather similar to a “Precautionary Principle Scenario” so that the risk management is (particularly regulatorily) focused on labeling consequences. (although some situations [see earlier link] may exist where measures to minimise cross-contamination are accepted as managing the risk combined with "visually clean" validations).Any labelling may depend on yr precise location / destination I guess.

Not quite sure of the exact process you are querying, eg – (a) the product mix intrinsically contains allergenic components or (b) the product may be cross-contaminated from some other allergenic product mix / line. If (a) the conclusion is probably well fixed. If (b) the earlier links give a lot of advice.

If yr allergen management program is declared as a "Prerequisite Program" based on for example the procedures for minimising cross-contamination / labelling as in earlier links (I realise the labelling may depend on your specific regulatory situation) this should reduce yr requirements regarding the HACCP choice of “severity” etc ?. :whistle: (If not, some more details as to yr process / hazard analysis might help).

(Actually if someone brings out a fast , cheap multi-allergen measurer, the potential looks good)

Rgds / Charles.C

added - these are only general examples but might be of interest

http://www.foodrisk....SRA-Dec2006.ppt

http://www.applegate...rgies_FAQ.shtml

http://www.ifav.de/0...mensions_FA.ppt

added (2) the terms risk, likelihood, severity etc are used in normal (NON- ISO) HACCP in various ways as I'm sure you know, in the context of the "normal" risk assessment I enclose this for yr consideration

Attached File  risk_matrix_7.pdf   16.42KB   209 downloads
or
Attached File  risk_matrix_8.pdf   132.25KB   174 downloads


Kind Regards,

 

Charles.C


Lalith Gunatillake

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Posted 11 June 2007 - 11:34 AM

Dear Aphro,

There is an act for allergenic compounds called "FOOD ALLERGEN LABELING AND CONSUMER PROTECTION ACT OF 2004 (FALCPA). It might be helpful if you can read it. Please do a netsearch for it. If I get the link I will put it to forum.
Thanks sorry for not having the link,
Lalith



Lalith Gunatillake

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Posted 11 June 2007 - 12:10 PM

Please go to this site and see. http://www.cfsan.fda...dms/alrgqa.html
Lalith



aphro

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Posted 09 July 2007 - 08:39 AM

Dear everybody,
Thanks for all the input. Sorry, for my late response due to serious trouble with my notebook, it took a long time to fixed it

After I read through the references, I made a conclusion for implementation guidance :
1. we have to identify, whether our ingredients contain allergenic compound
2. if yes, we have to established allergen management programme, and it could be integrated within our PRP
3. we also have to identify the regulation related with our product which known contain allergen compound (labeling requirements )
4. the labeling management can decide one of two method as mentioned in the FOOD ALLERGEN LABELING AND CONSUMER PROTECTION ACT OF 2004 (FALCPA)

but, I am still have further question :

1. I am still not clear about hazard analysis : if our ingredients contain allergenic compound, should we put allergen in the hazard analysis table, because this allergen will be exist in the whole processing step until final product ? if yes, it should be a 4th hazard or can be categorized as one of chemical hazard ?

2. according to reference : FOOD ALLERGEN LABELING AND CONSUMER PROTECTION ACT OF 2004 (FALCPA), if we are working with food processor like : restaurant, café, it is not mandatory to put in our product label about allergen ( it was really sure this processor using milk, wheat flour, egg in their product ), isn’t right ?? please correct me if I’m wrong.

I would be happy if anybody can response about it,

Regards
Aphro



Charles.C

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Posted 09 July 2007 - 03:48 PM

Dear Aphro,

Did you notice the related comments posted in June + in this thread? - http://www.ifsqn.com...?showtopic=2582

Rgds / Charles.C


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Charles.C


aphro

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Posted 12 July 2007 - 03:40 AM

many thanks, charles..
I will explore it

regards
aphro






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