As allergen control is identified as one of the 10 fundamental clauses of the BRC Global Food Safety standard, FBOs, (Food Business Operators), need to have a structured approach to managing allergens within their operation.
A practical way of ensuring that your allergen management programme is fit for purpose is to ensure compliance with the 10 point allergen improvement plan.
1 Allergen policy As allergens are 1 of the 4 food safety hazards, companies need to develop an allergen policy to demonstrate their commitment to legal compliance.
2 Risk Assessment As all contempoary Food Safety standards are based on risk assessment, each manufacturing process step needs to be risk assessed for the potential of allergen x contamination.
3 Supplier Management As a significance number of allergen x contamination incidents occur off site at supplier locations, suppliers must be risk assessed for the potential of allergen x contamination.
4 Recipe/Spec Control All manufacturing recipes and other product specs need to address allergen content to ensure that required information is shared between businesses in the food chain.
5 Labeling Review All finished product labels must be validated prior to use to ensure that they comply with all relevant Labellling legislation, ref Commission Directive 2007/68/EC annex 111A.
6 Operational Control All risk assessment evaluations undertaken by the food safety team must be transferred to factory floor manufacturing operations to ensure the relevant knowledge is in place.
7 Cleaning Validation All cleaning operations which historically focussed on the elimination of microbiological, biological and chemical hazards need to be re-validated to ensure the same procedures are capable of eliminating allergenic hazards.
8 Employee Training All staff, via induction training or specific on-the-job training, need to be made aware of the allergen risks in the manufacturing environment.
9 Change Control/Change-Over When allergenic and non-allergenic materials are processed on the same manufacturing equipment, change over procedures need to be formalised to ensure x contamination does not occur and the correct label is applied to the new manufacturing product.
10 Consumer Data FBOs, in an effort to demonstrate due diligence, need to investigate all possible means, (product labeliing, product websites), to inform consumers of the risks associated with products being produced.
If this 10 point allergen improvement plan is followed by food businesses, they can demonstrate that they are taking a structured and logical approach to allergen management.
Our next public Food Allergen Control training course takes place on 23rd April in Dublin