Allergen management is not just about sticking a “may contain…” label on products. A formal documented control system should be in place addressing each step in the process from receiving through to dispatch. There are some tricky areas that needs more in-depth discussion. We asked Ron Timm, a well respected industry expert for some more advice...
What about rework of product that contains allergens?
RGT: Rework constitutes a significant allergen cross-contamination risk in the food industry, particularly when it is held over to a subsequent production run. Many companies have opted for a 'No Rework Policy' since the cross contamination is not limited to allergens, but also to microbiological or even chemical and physical contaminants.
In some cases, however, rework is essential but the important principle is to ensure that it is reworked into the same product and preferably during the same production run. One quite often comes across uncontrolled rework stored around food factories and this subject needs to be formalised through detailed policies and procedures which leave no room for misinterpretation or abuse. Verification that the procedures are correctly followed is paramount and one always needs to ensure that 'the words match the music'.
You should:
- Define your rework policy
- Rework allergen containing product into the same product and preferably the same production run
- Develop and implement robust procedures
What about new product development?
RGT: The introduction of new allergens into a food plant or production line though new products or new ingredients needs to be controlled. Any new ingredient needs to be thoroughly screened to identify allergens it may contain, while the Allergen Policy needs to cover new product development activities. Many companies have adopted a policy that only where it is essential will any allergen be permitted in a new product. In such instances, tight controls to prevent cross contamination to existing products need to be developed and implemented before any factory trials on existing equipment are contemplated. The substitution of ingredients in existing products due to non-availability, or for purposes of cost saving, are often practiced in the industry and allergens need to be considered when assessing the feasibility of the substitution.
You should:
- Screen any new ingredients for hidden allergens
- Pay attention during factory trials
- Pre-screen any substitution ingredients for out of stock situations
What about the people?
RGT: People handling and working with allergens in one area can be a source of cross contamination if they enter an allergen-free area, and control of access to sensitive areas needs to be considered. The creation of 'allergen barriers' through the locking of doors which previously allowed free access is being practiced more frequently. Hand washing is normally mandatory if one moves from one allergen area to another and clothing changes may be warranted, depending on the circumstances.
You should:
- Dedicate areas for allergen handling
- Segregate staff
- Implement handwashing and changing of clothing when moving between areas
Is a warning label not the best allergen control mechanism, so the consumer can decide?
RGT: Labelling of all deliberately-added allergens is a regulatory requirement in most countries including South Africa. The ethics of defensive labelling ('may contain xyz') is a controversial subject which has sparked much debate and should, in any event, only be used as a last resort rather than as an excuse for sloppy manufacturing control. Finally, the matter of testing or screening for the presence of allergens in products where they should be absent is more and more frequent and this is sometimes a customer requirement. This is particularly necessary for the validation of a cleaning procedure where shared lines are involved. Not many companies do this screening themselves, but rely on outside services. The existence of a competent laboratory in South Africa now obviates the need for costly overseas testing.
- Include allergens on the labels
- Only use a warning as a last resort
- Implement a verification programme to confirm the absence of allergens in non-allergen containing products.
Allergen management requires attention and commitment. It’s not easy but it better than trying to salvage a damaged brand.
References: Adapted from “Managing allergens in the food factory”– Ron Timm, Food Review, January 2007
Author
Ron Timm
