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A sensitive situation

Proper allergen control procedures can be a matter of life or death. Jo Paxton, head of product and supplier assurance at international food safety and assurance firm NSF-CMi, explains how manufacturers can to rise to the challenge

It is estimated that approximately one-two per cent of the adult population in the UK and about five-eight per cent of children have a true food allergy. That equates to about 1.5 million people.

Most allergic reactions to food are relatively mild, however, sometimes they can be very serious. Occasionally, reactions can be fatal – with approximately ten deaths a year in the UK attributed to food allergy.

Last year, 57 allergy alerts were issued by the UK Food Standards Agency, leading to costly recalls for companies – both financially and in terms of reputation.

Guidelines for manufacturers
So what can manufacturers do to safeguard both the consumer and their business?
NSF-CMi has drawn up guidelines to help manufacturers achieve effective allergen control by managing risk throughout the supply and production process.

Raw material and supply chain control
• Ensure all suppliers are approved to supply each raw material via questionnaire or audit
• Assess status of all raw materials. Be aware of the presence of all allergens in all raw materials, paying particular attention to the potential for cross contamination from manufacturing and handling activities on the supplier’s sites, as well as earlier in the chain during harvesting and transport.
• Order against clear specifications and ask whether an ingredient contains allergens either as:
a) A major component (eg textured vegetable protein from soya)
b) A minor component (eg as a food additive or processing aide derived from an allergenic source, eg amylase from wheat)
c) Cross contamination (eg chickpea flour from a mill that also mills wheat)
• Store allergenic materials in clearly identified areas, eg colour coded boxes or demarcation of storage areas using painted lines on the floor.
• Where allergenic raw materials are de-bagged or de-boxed, they should, if possible, be handled in a dedicated area away from other products to prevent cross contamination, be placed in dedicated lidded and labelled containers and made easily identifiable. Such containers should only be used for storage of other raw materials after appropriate cleaning. If allergenic ingredients are sieved, then the sieving unit should be either:

(i) Dedicated or (ii) thoroughly cleaned after sieving allergenic ingredients.

If possible, allergenic ingredients should be sieved after all other raw ingredients have been sieved for the day.

Premises, equipment and processes
The best approach to avoiding cross-contamination with allergens is to dedicate production facilities to specific allergenic products. However, it is recognised that this is not always an option particularly in small businesses. Where dedicated production facilities are not possible, there are a number of ways of separating the production of allergen containing products from those that do not contain the allergen. These can include separation:
• in different parts of the production area
• by using physical barriers between the production lines.
• by use of dedicated equipment
• by minimising unnecessary movement of materials.
• by appropriate scheduling of production runs, including appropriate cleaning of equipment between production runs.
• by managing rework, ensuring that residual material containing an allergen is not reworked into a product not containing the allergen
• by separating the air supply, where practical.

Shared equipment
Where possible, consideration should be given to the dedication of equipment within production facilities. For example, weighing equipment, scoops and utensils could be dedicated and the weighed product placed in dedicated, lidded and labelled containers. Consideration could be given to colour coding equipment, although this may not be practical where a number of allergens are being handled, and/or colour coding is used already for other purposes, such as the identification of cooked or raw ingredients, or vegetarian products.

If it is possible to dedicate areas or equipment, it is important to avoid allergen cross-contamination between these and other operations, including managing the movement of equipment, personnel, vehicles and maintenance tools.

Physical separation
Physical separation should be considered for ‘high risk’ ingredients and the implications of changes to the layout of the food production area should be assessed. Consideration should also be given to the ease of cleaning of equipment. Avoiding the crossover of production lines and allowing adequate space for effective cleaning will help minimise the risk of allergen cross-contamination.

Airborne particles
Consideration should be given to the implications of air movement. For example, where nut products and nut free products are produced in the same production area it may be possible to dedicate air conditioning/extraction fan systems to contain nut dust, or positive pressure may be used in nut free rooms to prevent nut traces entering the room on the air. When scheduling production runs, consideration should be given to scheduling those products not containing the allergenic ingredient first. Additionally, long runs of allergenic products should be undertaken wherever possible, to minimise changeovers and these should be followed by a major clean down.

Storage
Consideration should be given to the temporary labelling of work in progress. This is, for instance, a half-finished product that is held-over. Care should be taken that the product is not mistaken for another product with a different set of allergens. Similarly, care should be taken to label and store packaging materials that are unused at the end of a production run. Co-products are misshapes and broken products, which for quality reasons are not acceptable as finished product but could still be consumed by employees or sold through factory shops. Such products should be subject to the normal allergen labelling controls.

Rework
Rework that contains allergenic ingredients should be reworked only into products that contain that particular allergen. Rework should be clearly identified in order that it may be tracked in the manufacturing process.

Cleaning
Very small amounts of some allergens, eg nuts, can cause adverse reactions in certain individuals, including potentially fatal anaphylactic shock. Therefore, thorough cleaning that is effective in reducing the risks of allergen cross contamination should be used where appropriate. A ‘visually and physically clean’ standard is not just a casual visual inspection of the production line or area, it also requires that all of the trouble spots are sought out and inspected. Cleaning practices that are satisfactory for hygiene purposes may not be adequate for removing some allergens and their validity for such a purpose should be assessed, eg via residue swab testing. When an appropriate cleaning method has been approved for use, its effectiveness should also be monitored on a regular basis with swab testing.

Packaging
Incorrect packaging and/or labelling is a major cause of allergen- related product recalls. Procedures for checking that the correct labels are applied to products should be implemented and audited regularly, in order for accurate information to be provided to consumers.

NPR & reformulation
The introduction of a new product or any changes to existing products or production process within the food production area can affect the risks of allergen cross-contamination of other products. Following any such changes, it will be necessary to conduct a new assessment of the risks of allergen cross-contamination of a product, including an evaluation of any advisory labeling that might be necessary.

People & training
All staff (including temporary staff and contractors) involved in handling ingredients, equipment, utensils, packaging and products should be aware of food allergens. They should be trained in avoiding cross-contamination of foods by the major food allergens. Appropriate procedures on the management of allergens should also be available and/or posted wherever they need to be observed.

Further safeguards
In January this year, NSF-CMi launched its Allergen Due Diligence Assessment (ADDA) designed to provide independent assessment of allergen control procedures implemented, and to provide advice relating to industry best practice. The ADDA standard is the first end-to-end review of the whole manufacturing process with on-site risk assessments that focus on the real risks present.

 

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