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19/10/17: Putting together an effective allergen control plan

8A7B2167-353A-4708-A10A53026024A934Labeling of foods for the presence of allergens must identify all foods that intentionally contain the particular food or ingredients derived from that food. However, voluntary labeling for the possible presence of the allergen should be reserved for genuine hazards.

There has been a proliferation of the use of such precautionary allergen statements, which range in wording from “May Contain” to “Processed in a Facility” to “Made on Shared Equipment.”

This increase has limited consumer food choices, and for food-allergic consumers, the tendency to ignore precautionary statements and take risks regarding the foods they choose to eat is on the rise.

According to the Food Allergy Research and Resource Program in 2003,[1] possible processing errors or oversights that result in allergen-containing product contamination are as follows: inadequate cleaning of shared equipment (nonallergen-containing products run after allergen-containing products, resulting in cross-contamination); use of rework (not using “like into like” practices); switching of ingredients (and not following up with an allergen assessment of the new ingredients); labeling terms (using uncommon or incorrect terminology for the top eight allergens); and frequency of Hazard Analysis and Critical Control Points plan review.

It doesn’t matter what the cause—leftover ingredients in a hard-to-reach corner of your processing line, a halfhearted cleaning effort due to employee fatigue or a looming product deadline—any allergen residue not adequately cleaned and removed from your processing line can find its way into the next product on the line, causing your next product to inadvertently contain an allergen not included on the label—and that can have grave consequences. It’s a matter of process design, protocol documentation and thorough validation of cleaning procedures—and your allergen control plan (ACP) needs to account for it all.

Getting Started

As more and more food product recalls are due to undeclared allergens on labels, it is essential that all companies implement an effective ACP to avoid inadvertent allergen cross-contamination, damaging recalls and adverse, or even deadly, effects for consumers.

An ACP is a systematic method for identifying and controlling allergens, from the incoming ingredients to the final packaged product in any food processing facility.[2] It is your company’s written documentation regarding the storage, handling, processing, packaging and identification of allergenic foods and ingredients.

The fundamentals of developing an effective ACP in the food plant are discussed below. For other resources, please see “Food Allergen Resources.”

It should be noted that this is not a one-time effort. Your ACP must be implemented, audited, enforced and updated continually.

Every time you make a change in a process or a product, assess the ACP and update it if required.

For example, every time you hire a new employee or change the job tasks of an employee, make sure he or she understands his or her role in the ACP through training that is documented.

Every time you begin working with a new supplier, evaluate the supplier’s ACP and alter yours as needed. If you change or add plants, a new ACP should be developed to reflect these changes.

An ACP is not only about protecting the health and confidence of consumers but about protecting your brand as well.

The Fundamentals

The first step in developing your ACP is to identify people in your organization who understand not only how ingredients enter and travel through your facility but also the vital importance of managing and controlling these ingredients at every stage of production: from choosing suppliers to handling, storage, processing, packaging and labeling.

Let’s look at a few of these critical steps:

Review Suppliers. What comes into your facility from suppliers can have an important impact on the quality and integrity of your food processing procedures—and ultimately can affect the brand. Your ACP should outline expectations, documentation and validation to ensure that your suppliers are diligent and dedicated to the control and management of allergens.

Food manufacturers should obtain copies of product or ingredient formulations, specification sheets or certificates of analysis from suppliers of raw ingredients.

When reviewing specifications, you should look for formulations that list ingredients without a sublisting. For example, whipped marshmallow may contain eggs, or soy sauce may contain wheat. In many cases, the final concentration of the allergen contained within another ingredient is so low that it should not cause illness.

However, testing to verify the amounts of allergen present will help determine whether actions are needed within the plant. Verify that your suppliers have an ACP.

Raw Ingredient Storage and Color-Coding Systems. Store all allergenic foods or ingredients derived from these foods in an area that is secluded from nonallergenic materials.

If this is not possible, require that all incoming pallets are shrink-wrapped to prevent cross-contamination opportunities, such as leakage from torn bags.

Carefully store partially used bags and containers of allergen-containing ingredients in segregated areas. Verify that production staff seals all partially used bags and containers.

Allergen identification is a helpful tool for all employees in a production facility. All raw ingredients that are allergens should be labeled with a tag that states “allergen.”

This will help avoid substitution mistakes (e.g., wheat flour for soy flour). A color-coded tag also may be used. It is recommended to place color-coding charts throughout the production area, especially above all equipment and near storage areas for easy identification by plant personnel.

Store allergenic compounds on bottom racks or points nearest to the floor to avoid spilling allergenic ingredients onto nonallergenic items below.

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