In need of help with Allergen Management Program

Good day everyone, I work for a chocolate company that produces all kinds of chocolate products. We do not have any allergen program right now but I am proposing we do because we have to somehow. It is going to be very difficult to separate allergens at this plant because chocolates have to be tempered and its also a small business. Tempering machines used for allergen product are being used for non allergen product especially when the enrober is been used to enrobe the chocolate. They have a statement on their product that says all products were produced in the same facility as nuts, treenuts, diary, wheat ..... etc. Is this statement enough?When we use our molds for dark and milk chocolates we segregate them but there is milk in both of the products and I just told them if they are segregating them because of milk, its not necessary. Please, I need some clarity. Thanks.

If milk is present in all, no reason to separate.

As to the blanket statement of being produced in a facility that also processes nuts, treenuts, dairy, wheat, etc - not good enough.

You need a fully vetted and implemented allergen control program as right this moment your company is sitting duck awaiting a bullet that will come.

If milk is present in all, no reason to separate.

 

As to the blanket statement of being produced in a facility that also processes nuts, treenuts, dairy, wheat, etc - not good enough.

 

You need a fully vetted and implemented allergen control program as right this moment your company is sitting duck awaiting a bullet that will come.

Thank you so much. I feel the same way and I have let them know we are a ticking time bomb. I am new here and I am learning a lot about chocolate. And also due to the fact that we do dry cleaning too with regards to sanitation, how do we really manage for allergens? These tempering machines run for weeks unending. Water is not chocolates friend so I have learned.

No need for separation, as indicated by Mr. Glenn above.

You will, however need an allergen program outlining your reasoning, along with the implementation appropriate storage practices of raw materials that contain allergens, etc.

The statement "all products were produced in the same facility as nuts, treenuts, diary, wheat" is not gonna cut it with the Feds or a 3rd party auditor.

A very preliminary thing for you to think about as you build your program - it can be helpful to group allergens into three categories. Each category needs its own plan.

1) allergens that are intentionally included in EVERY product you make. For example, maybe milk. This is the simplest category because you just need to be certain that your labeling is clearly warning anyone with a milk allergy to stay away.

2) allergens that are intentionally included in SOME products you make. This might be nuts, wheat, etc. For this category, you need a lot more. How are you storing these ingredients, how are you cleaning equipment after you use these ingredients, how are you ensuring there is no cross-contact, etc etc etc. There are a lot of threads in this forum that can help you get started! 

3) allergens that are intentionally included in NONE of the products you make. Shellfish, I'd imagine. You still need a plan for these, and the big question here is, "how can I be confident that these allergens are not accidentally incorporated into my products?". Your answer will likely involve some combination of supplier guarantees, testing of incoming ingredients if your supplier guarantees are wobbly, policies around foods employees bring from home or purchase from vending machines, etc.

Good luck!

I too work for a chocolate confectionery company. As far as most chocolates whether they are milk, dark or sugar free they contain milk and soy. You need to have an allergen plan and the FDA or any third party audit will look intently at it. I would suggest you do some allergen testing on the chocolate in your enrober to see if the constant addition of chocolate has the desired affect and some on finished product. ATP testing and some allergen swabbing on the food contact surfaces will give you an view of where you are at. You can use those to begin an allergen program. Advisory labels are just that and are not a defense if something happens to a anyone.

I too work for a chocolate confectionery company. As far as most chocolates whether they are milk, dark or sugar free they contain milk and soy. You need to have an allergen plan and the FDA or any third party audit will look intently at it. I would suggest you do some allergen testing on the chocolate in your enrober to see if the constant addition of chocolate has the desired affect and some on finished product. ATP testing and some allergen swabbing on the food contact surfaces will give you an view of where you are at. You can use those to begin an allergen program. Advisory labels are just that and are not a defense if something happens to a anyone.

Good Day austij01,

I am new (2months now) in the chocolate business and I would appreciate it if you will be a resource for me. I am writing SOP's and procedures and I want to make sure I don't leave anything out and any other information I need. I am a quality department of me, myself and I. Thanks

Since you mentioned it is a small company and the same manufacturing lines are used for multiple products, you Allergen management could be based on following:

1. Segregation in storage of Raw and Finished products.

2. Labeling and also Label control. As mentioned above the advisory statement might not work.

3. Line (allergen) changeover Procedures, which should include Allergen swabbing of any previously run Allergen on the same line. Kits are available for quick results (e.g Neogen, Hygiena, etc.)

4. Utensils control (color coding of utensils based on Allergen profiles could help).

Since you mentioned it is a small company and the same manufacturing lines are used for multiple products, you Allergen management could be based on following:

 

1. Segregation in storage of Raw and Finished products.

2. Labeling and also Label control. As mentioned above the advisory statement might not work.

3. Line (allergen) changeover Procedures, which should include Allergen swabbing of any previously run Allergen on the same line. Kits are available for quick results (e.g Neogen, Hygiena, etc.)

4. Utensils control (color coding of utensils based on Allergen profiles could help).

Thank you so much. This helps a lot. 

Maybe of background interest -

 

https://www.ifsqn.co...ccp/#entry73185

https://www.ifsqn.co...ens/#entry67526

 

IIRC there are a few threads here on chocolate enrobing lines if you don't mind a little searching.

Thank you so much Charles.C. This was really extensive. I appreciate it!

Hello Everyone

In context to above conversation, I work for Bakery where it is almost impossible to eliminate allergens as n number of products among those most of the products contain milk, soya, eggs ,wheat, gluten just only couple has one or the other allergen i.e. peanuts (peanut butter) tree nuts sulfites. As mostly allergens are present in products we considered Peanut as a Chief Allergen of the facility against which we validate our sanitation program. According to the ingredients specifications allergen profile is created for the products. Products falling in the same profile can be baked at same time or same day using different equipment. But those with different profile are scheduled either on the different days or after finishing the generic allergen profile products (That contains majority allergens of the following product except 1/2 different allergens)

Our bakery is slowly trying to implement the 100% effective Allergen Management Program, but for a start up we are doing good and improving day by day.

Hello Everyone

In context to above conversation, I work for Bakery where it is almost impossible to eliminate allergens as n number of products among those most of the products contain milk, soya, eggs ,wheat, gluten just only couple has one or the other allergen i.e. peanuts (peanut butter) tree nuts sulfites. As mostly allergens are present in products we considered Peanut as a Chief Allergen of the facility against which we validate our sanitation program. According to the ingredients specifications allergen profile is created for the products. Products falling in the same profile can be baked at same time or same day using different equipment. But those with different profile are scheduled either on the different days or after finishing the generic allergen profile products (That contains majority allergens of the following product except 1/2 different allergens)

Our bakery is slowly trying to implement the 100% effective Allergen Management Program, but for a start up we are doing good and improving day by day.

Thanks Sharma. I feel like the knowing and the effort in getting the program started is a starting point and being able to convince my DOP that we can't hide from creating an allergen program or hide under a blanket statement after he attended the PCQI class is a plus for me. We are also a growing company so there are so much hurdles to jump. 

There is a wealth of knowledge on this site and I have read and used much of it in formulating our Allergen Plan and creating a Food Safety Plan. I'm a newbie to posting on this forum and now hope to become more of a contributor. We had our first BRC Audit this week and did very well getting a Grade of A. Working with many allergens it is a must to have a plan in place that addresses the issues of cleaning and scheduling to create a safe product for all customers. One thing I have found whether writing an allergen or sanitation plan down to SOPs and Work Instructions is to create it, have those that will use it read it, test it and edit when necessary. Most of all keep plugging away no matter how daunting the task appears to be. Attached is a document put out by he FDA that has some relevant information to use for an Allergen Plan