17 replies to this topic

[Simon]

Can anyone give details of what you do to prevent the food products you produce becoming contaminated by allergens such as nuts, transferred by employees.

I’m talking more about the controls on eating and drinking, vending machines (allergen free menu), and employees bringing in personal foodstuffs from home and the shop etc.

Thanks,
Simon

[hacked]

We addressed this issue by implementing hygienic zoning and discussing the basic DO's and DON'Ts during the rollout of the zoning requirements. Bringing food (an allergen or not) inside our processing area is also considered a cGMP violation. Eating is only allowed inside our cafeteria and food brought in by employees will be kept within our canteen area.

[Simon]

We addressed this issue by implementing hygienic zoning and discussing the basic DO's and DON'Ts during the rollout of the zoning requirements. Bringing food (an allergen or not) inside our processing area is also considered a cGMP violation. Eating is only allowed inside our cafeteria and food brought in by employees will be kept within our canteen area.

But what about small or trace fragments of allergens such as peanut on clothing??

[hacked]

we have an ante-room before going inside our processing areas (a requirement for each hygienic zone). there is an ante-room linking two different hygiene zones. in this ante-room, personnel are provided with sets of appropriate garments (eg. overgown, face mask, shoe cover etc.) as required by the zoning of the area. hand sanitizers are also placed in the ante-room.

Edited by hacked, 03 July 2007 - 07:14 AM.

[Simon]

we have an ante-room before going inside our processing areas (a requirement for each hygienic zone). there is an ante-room linking two different hygiene zones. in this ante-room, personnel are provided with sets of appropriate garments (eg. overgown, face mask, shoe cover etc.) as required by the zoning of the area. hand sanitizers are also placed in the ante-room.

So of course work clothing is changed before visiting the canteen or bathroom etc.

[Charles.C]

Dear Simon,

Warnings on / in canteen and bathroom -

NUTS NOT ALLOWED IN THIS AREA

+ Validation / Verification

Rgds / Charles.C

[hacked]

Sir Simon,

Yes, as required by the hygienic plan.

Sir Charles,

You prohibit bringing in allergens into the area? That's probably the best way to prevent contamination.

[Charles.C]

Dear Jong,

I took a cheap way out which also looks good to the visitor / auditor but –

Everything has a risk. Prohibition is easy – the Precautionary Principle is a natural human reaction. The problem is how to get a balance or you end up with an ultimately unworkable system IMO.

For example, I believe chicken meat handling is “recommended” to be carried out in a controlled factory environment of

[Simon]

Sir Charles, I think the UK law on working temperature is wishy washy. The word comfortable is mentioned a lot. It depends on the clothing worn, how strenuous the job, humidity, air flow, how many people are complaining etc.

What is thermal comfort

BTW what has this got to do with allergens.

Regards,
Simon

[Charles.C]

Dear Simon,

You can jump to last para. if really in a hurry

Didn't see any EU opinion but -

The temperature in workrooms should normally be at least 16 degrees Celsius unless much of the work involves severe physical effort in which case the temperature should be at least 13 degrees Celsius.

http://www.hse.gov.u...temperature.htm

Temperature is an important aspect of the working environment. Every
individual has an optimal temperature at which he/she is comfortable and can
work most efficiently. Several bodies have set out guidelines for optimum
temperatures for different types of work. For offices and sedentary work, there
is a statutory minimum requirement of 16?C but an optimum temperature
range of 19?C - 24?C recommended.

http://www.ulster.ac...y/PDFS/3.14.pdf

To return to yr original topic, I have never seen a recorded incident matching yr question although I can understand the possibility. Did you have a specific situation in mind, eg factory producing peanut bars alongside other sensitive items ? I did notice a discussion on this subject on a peanut manuf. website but it only seemed to regard the process as a significant risk.

Rgds / Charles.C

[Simon]

You can jump to last para. if really in a hurry

Didn't see any EU opinion but -

The temperature in workrooms should normally be at least 16 degrees Celsius unless much of the work involves severe physical effort in which case the temperature should be at least 13 degrees Celsius.

Temperature is an important aspect of the working environment. Every
individual has an optimal temperature at which he/she is comfortable and can
work most efficiently. Several bodies have set out guidelines for optimum
temperatures for different types of work. For offices and sedentary work, there
is a statutory minimum requirement of 16C but an optimum temperature
range of 19C - 24C recommended.

So they do mention specific temperatures. There does not appear to be a maximum though, perhaps with global warming they are trying to prevent mass walk outs.

To return to yr original topic, I have never seen a recorded incident matching yr question although I can understand the possibility. Did you have a specific situation in mind, eg factory producing peanut bars alongside other sensitive items ? I did notice a discussion on this subject on a peanut manuf. website but it only seemed to regard the process as a significant risk.

My original query was for a packaging factory that does not manufacture anything to do with nuts or any other allergen for that matter. I simply wanted to know what controls should be in place re canteens, vending machines, employees bringing in food from outside to prevent any incidental contamination of products by way of personnel e.g. on work clothes etc. In this factory employees can eat and drink whilst wearing their work clothes. What is the chance of a fragment of peanut getting onto work clothing and being transferred to food contact packaging and then from the packaging onto the food and then into the body of someone with a peanut allergy. I guess the risk is minute, but it is probably good practice to change into civilian clothing when eating or drinking anyhow.

Regards,
Simon

[Charles.C]

Dear Simon,

Exactly as you say, the clothing parameter is not always so easy in practice.

This is the problem with HACCP, it makes you think (too) much! Any evidence of such an incident having occurred ? How big a possible consumer catastrophe. Obviously one can tailor the prerequisite program to minimise.
Risk = VL x VH >> ??

A related (food) question is - How much warning of allergen content should be given on the label other than by ingredient list ??


Rgds / Charles.C

[Charles.C]

Dear Simon,

It doesn't answer yr original question but I would love to know if this link via the Newsgirl alert refers to the type of situation you were referring - guess we'll never know - I don't understand why zero details are always given [part of the deal in voluntary recalls ?], surely the object should be to help prevent recurrences in general ?

There is a small possibility that these products have been cross-contaminated with peanuts during an isolated incident at the factory

http://www.food.gov....2007/jul/peanut

Rgds / Charles.C

[Simon]

A related (food) question is - How much warning of allergen content should be given on the label other than by ingredient list ??

Is this related to the other allergen thread. e.g. "may contain"?

It doesn't answer yr original question but I would love to know if this link via the Newsgirl alert refers to the type of situation you were referring - guess we'll never know - I don't understand why zero details are always given [part of the deal in voluntary recalls ?], surely the object should be to help prevent recurrences in general ?
http://www.food.gov....2007/jul/peanut

Could be Charles, but I expect it was an ineffective clean down or something or someone breaking the rules. Another flawed system. Poka Yoke?

[Charles.C]

Dear Simon,

Indeed, nothing like a bit of Hoki-Poki

Rgds / Charles.C

[Simon]

Indeed, nothing like a bit of Hoki-Poki

I like dancing too Charles, but are you a human error or systems failure type of guy?

[Charles.C]

Dear Simon,

I believe the correct spelling is Deming.

I suppose that proves yr point

Rgds / Charles.C

added - here's another one -

“It does not happen all at once. There is no instant pudding.”

He'd obviously never met Tony Blair.

[Simon]

Dear Simon,

I believe the correct spelling is Deming.

I suppose that proves yr point

Rgds / Charles.C

It wasn't me.