Food recalls happen daily. These are reported and published in the US. An analysis of a sample of recalls reported recently in the US showed that more than 60% were due to the presence of undeclared allergens. This is a topic which needs to be given high level attention by food manufacturers since the adverse publicity and economic consequences can be severe. We asked Ron Timm, a well respected industry expert for some advice:
Where can one find practical information on how to manage allergens in the food industry?
RGT: To assist with this process some information has appeared in the literature and useful guidelines have been published (see references) and I would suggest that readers consult these since it is not possible to cover the subject fully in an overview such as this.
References you should consult:
Mills C et al: Managing allergens in Food, Woodhead Publishing, 2006
SANS 10049 Food Safety Management SABS Annex C
South African Food Cosmetics & Disinfectants Act Regulations R 146 as amended
Guidelines to Regulation R 146 – South African Department of Health
Guidance on Food Allergen Management for Food Manufacturers, FoodDrink Europe, Jan 2013
A documented Allergen Policy which sets out management's intentions in regard to the use, control and labelling of allergens is essential. This policy then needs to be communicated and implemented through a system of procedures, controls and records. Training to ensure that all staff fully understand the procedures and controls is obviously necessary, together with a system of regular checks and audits, to verify compliance followed where necessary, by corrective action.
Top 5 take aways
• Make sure you do some research to fully understand the risk.
• Develop an allergen policy – what is your standpoint
• Develop procedures and records
• Train your staff specifically on allergens
• Conduct regular thorough audits to assess the effectiveness of measures
What role does HACCP play in an allergen management programme?
RGT: HACCP is a key element of any allergen management programme for companies who have embraced and implemented this system and this fact is invariably covered in the policy. One of the first practical steps is generally to determine the risk of allergens being present in the raw materials, processing aids and packaging materials purchased. In some cases, these will be present intentionally, but one must also consider the risk of unintentional allergen cross contamination in these materials during handling and transportation to your plant. This is most often done in the form of a questionnaire which is sent to all suppliers of these materials. One needs to weigh up whether this questionnaire should be completed by the original prime source of the material (in the case of sealed containers of the material), or some other party along the supply chain where cross contamination may occur. These questionnaires are, for the most part, detailed and searching and the risk of accidental cross contamination prior to receipt at the factory needs to be fully explored.
Top 5 take aways
• HACCP will assist in understanding the risks
• Know what’s in your raw materials
• Check every raw material
• Ask your suppliers the difficult questions about how they handle allergens.
• Assess the risk of cross contamination
How does one practically apply allergen control measures?
RGT: Procedures for the handling of allergenic raw materials on receipt at the plant need to be developed and documented. As an example, these materials are frequently labelled 'Allergen' on arrival and then stored in segregated areas. One needs to take particular care of leakages and spillages from damaged containers and Spill-Clean procedures need to be in place, while colour coding can be used effectively to identify different allergens.
Plant design, layout and the extent to which product is exposed in the process, along with cross flows in the factory, can be serious risk factors in cross contamination. The use of shared equipment, utensils and handling equipment needs close scrutiny since this raises the question of how effectively they can be cleaned to remove all traces of allergens from previous product runs before starting a production run where the allergens are not declared on the label.
The validation of the cleaning procedure is very important along with the necessity to ensure that it is applied correctly before each changeover. lt is generally necessary when using shared equipment to formally schedule production runs so that products containing no allergens are run first, and then those which do contain allergens are run later and followed by the validated cleaning procedure.
Top 10 take aways:
• Develop procedures for receiving
• Label allergens clearly on arrival
• Store in dedicated areas
• Use colour coding to identify different allergens
• Develop procedures for cleaning up spills
• Review plant design for possible contamination points
• Design out the risk by avoiding cross flows
• Use dedicated equipment and utensils
• Validate cleaning procedures
• Schedule production runs so that non allergen products are done before allergen containing products.
In part 2 we ask Ron about issues like rework, the people aspect and labelling.
Author
Ron Timm
