We have arrived at part 3 of our allergen controls and management blogs from Elevating Food safety Pty Ltd. WOW! What a response we have had. It is encouraging to hear all your heartfelt feedback and how serious you are with handling allergen management.
This week we would like to answer some questions for you.
Once allergen controls are in place how can we manage the controls?
We manage allergen controls through measuring compliance. The most effective process is completing a validation study at the conceptual stage when new allergens are being introduced into the facility. It is essential that we understand the process that needs to be set up and the end product characteristics we need to achieve. Once this has been established we can determine our validation plan to verify our labelling requirements and remove any potential allergen cross contact hazards.
Elimination is the KEY!
Our consumers who suffer from allergic reactions and anaphylaxis want to trust that products they purchase are safe to consume and be confident that every reasonable precaution has been taken by manufacturers or food handlers to prevent allergen cross contact issues occurring. As manufacturers and food handlers we cannot assure allergen free issues if we don’t validate and work on eliminating allergens by re-engineering the process or line.
How can we eliminate allergens ?
Allergens can be eliminated by setting up stringent allergen management controls that are applied to assist eliminating or confidently controlling your known or potential allergen cross contact hazards.
Training, training, training – it is very important to communicate to employees including functional managers critical allergen food safety requirements and highlight the consequences we or our consumers may face if we do not comply to company policies and procedures. Using worst case scenario is most effective as this clearly spells out what the worst injury consumers can suffer and how this will effect the company and individuals within the organisation.
Testing – know your facility, know your lines/equipment, know your procedures, know your practices and know your products. It is good manufacturing practice to conduct allergen swab tests on line and conduct product allergen testing to validate your process and verify you have no allergen cross contact hazards or identify hazards may be present that need to be eliminated.
Risk assessments – conduct risk assessments to determine if you have any allergen hazards or potentially can have hazards. Once established you can work on re-engineering out of the process.
Eliminate allergens off site – review your allergens, review your sales and determine if you can remove any allergens you do not have to use or if you can replace with non allergen raw materials. Work with new product development and establish policies highlighting which raw materials can be used on site and which cannot such as peanuts and lupins. Review allergens employees may bring on site such as peanuts and peanut butter and review allergen products supplied in vending machines ad decide how this can be controlled or what area can you limit as a space on site where such allergens (ie: peanuts) can be eaten.
Dedicated processing lines, areas or facilities – discuss the opportunity of making product off site where facilities do not have allergen cross contact issues or narrowing allergens used in a facility on a line or in a area where you can control and monitor more effectively. Implement uniform controls and people flow on site to prevent allergen cross contact issues.
Continuous improvement – conduct a gap analysis, set up an allergen focus working groups that have a set of objectives and meet regularly with experienced cross functional experts who can review current practices, global practices, conduct a benchmark study, how can we do things better, how can we lead, how can we control our processes better, how can we help our consumers that suffer from allergic reactions and most seriously anaphylaxis, how can we help raise allergen awareness with our consumers and employees.
Cleaning – do you have records to prove that cleaning procedures followed on line after use of allergens are effective and that the allergen protein has been removed. This must be proven to avoid any major incidents or recalls occurring. Various resources are available including assistance from major cleaning chemical companies who will work with you to ensure you implement effective allergen cleaning procedures and will train your staff once the procedures have been proven to be effective through validations.
Third party manufacturers and co packers – protocols need to be documented and implemented to ensure third parties understand their responsibilities and what your expectations and company policies are regarding allergen management and controls. This is very important as you need to be confident that the allergen controls and management are clearly understood and compliance will be met. You or your team may not be present on site often enough to measure adherence and compliance to set company allergen protocols and standards. If your third parties are not high risk they can have a very high impact on your organisation, customers and consumers.
Vendor Assurance Supplier Management – protocols need to be documented and implemented to ensure suppliers manage their responsibilities and understand expectations and company policies regarding allergen management and controls. You also need to understand your supplier’s allergen controls and procedures to avoid a product recall occurring from cross contact or incorrect labelling issues. You need to measure adherence and compliance to set allergen protocols and standards to ensure you are confident that your suppliers system will work. Needless to say as Australian food and beverage manufacturers we need to work together with our third parties and suppliers to provide our consumers and customers with safe products that do not pose a food safety risk, food allergic reaction, food intolerance or anaphylaxis.
Allergen policies and procedures are required to ensure we manufacture, handle, store and distribute food products safely. The policies and procedures do not need to be overly technical or highly sophisticated they just need to capture all key elements of your process and use of allergen raw materials on site that can cause cross contact hazards. Procedures that should be considered are new product development controls, controlling new ingredients introduced on site even during product trials, conducting allergen risk assessments, conducting allergen swabs, receiving supplier allergen declarations, PIF’s, VITAL and product technical data sheets, implementing CoA’S, letter of guarantees, conducting internal audits and supplier audits, implementing cleaning procedures, implementing rework, WIP procedures, separating and segregating allergens on site, labelling all allergens so they stand out, colour coding, conduct regular staff training and refresher training, complete ongoing product testing and equipment swabbing, implement new product development protocols and requirements, document product and line flows and establish clear product labelling.
A set timeframe needs to be established to measure compliance and validate regularly that cross contact hazards have not emerged. Validations are essential to ensure safe product is manufactured, handled, stored and distributed.
In summary, working in the food industry we know we need to control and manage allergen raw materials used on site or in our facility, our lines/equipment and our finished products. It is our responsibility as Quality Assurance professionals to ensure we meet our customer and consumer expectations when purchasing and consuming our products.
As food handlers or manufacturers we are responsible to meet legislative and customer requirements to ensure product quality & safety at all items. Food allergies affect 1 – 2% of Australian adults but are estimated to affect around 5% of young children. The numbers are growing and we cannot yet determine the actual cause. The difficulties of living with an allergy may not be known by many people however we may be able to help make a difference in the lives of those who do. We hear about farm to fork, paddock to plate or soil to shelf. I think we need to spend more time focusing and thinking about tongue to trauma, contact to crisis or desire to disaster.
We are Australia’s leading experts with allergen controls and management. If you need help call us on 02 8090 7650 or email Dijana Green on email@example.com for advice, training, internal audits or continuous improvement workshops.
Keep checking and keep training, yours in passion, Dijana Green.