With the increase of national recalls due to incorrect product labelling for allergens, below is information that can assist with allergen management and control from raw materials received to storage, production, packing, despatch and transporting of your finished product.
- Ensure allergen identification, control and corrective action is included in your HACCP plans.
- For example, due to the importance of allergen control, MQA develops HACCP plans using the following categories: Allergen, Microbiological, Chemical, Physical, Quality, and Regulatory.
- Although allergen cross contamination is recognised as a chemical cross contamination, by segregating allergen from chemicals within the HACCP plans, it allows for a comprehensive approach towards allergen control to ensure all potential risks are identified across all food processes from ordering and receival of raw materials to the transport of finished product.
Supplier Product Specification
- Supplier product specifications come in array of names: safety data sheet, food data sheet, product data sheet, finished product sheet, finished goods sheet, product information form or PIF (template offered freely from the Australian Food & Grocery Council afgc.org.au), etc.
- Obtain a product specification for all of your raw materials or resalable finished product.
- Ensure the product specification is current – check the version date. If no version date, request one from your supplier.
- Suppliers of raw materials that have lots of ingredients, such as chocolate, may update their product specifications more regularly than a supplier of a raw material with minimal or natural ingredients – keep an eye on this and know when to request an updated product specification.
- Perhaps speak with your supplier and be on their mailing list to forward all updated product specifications when they occur. Develop a relationship with your suppliers to encourage open communication.
- When received, match the product specification with the actual label on the packaging. Report back to your supplier if the information does not match.
- All food additives must be declared. Refer to FSANZ code Schedules 15 and 16 for a listing of all additives and how they must be declared on both the product specification and on the raw material/finished product labelling.
- Set a guideline on how old the product specifications should be. Perhaps set up a register of all product specifications. Once a year (or more often, dependant on your business needs), filter your register to be supplier specific and forward to your supplier, requesting updated product specifications if the date on your register does not match theirs.
- Example below of a register you can develop through Microsoft Excel. Use the filtering system to make supplier specific. Copy/paste filtered register into an email to the quality department of your supplier with your enquiry.
|ABC123||Diced Apple||124568||Diced Apple 2.5 kg||ABC Manufacturing||15-01-12|
|ABC345||Sliced Apple||124569||Sliced Apple 4.5 kg||ABC Manufacturing||28-01-10|
- There should already be an approved supplier listing located where received product is accepted. If feasible, ensure there is an allergen listing as well. If your business has a lot of raw materials, perhaps consider a simple sign that lists the allergens your facility accepts or rejects.
- Ensure all product received are effectively sealed, free from damage and potential cross contamination.
- For example, you do not want to accept a delivery of an opened bag of peanuts alongside a damaged carton of flour.
- Ensure staff that accept delivery know the allergens, so they know where to store product.
- Ensure staff are familiar with suppliers and their raw material products. Ensure staff are trained to recognise a difference in labelling – has a supplier updated their raw material without notifying you?
- Ensure staff know what corrective actions are to be addressed.
- Types of storage to consider is sealed raw materials (warehouse), opened raw materials (production), work in progress storage, cooling, packing, and finished product storage.
- When identifying your hazards through any storage process, consider potential cross contamination. Best way to identify is to do the walk. Walk alongside your processes or observe staff working to identify any gaps to improve your systems.
- It’s all about segregation. Segregate, segregate, segregate. Segregate your allergens. Don’t have much space? Who does? But the lives of your consumers are at risk here. To prevent potential cross contamination consider the below options.
Storage – Warehouse
- Develop signs. Ensure product is stored by designated signage.
- For example, ensure all peanuts are stored together by the peanut sign; ensure the eggs are stored together in the temperature-controlled equipment by the egg sign, and so forth.
- Do not permit staff to place an allergen product in a non-allergen area or by a different allergen product – ensure staff practice due diligence at all times.
- Consider having allergen products on lowest shelving.
- Remember cross contamination can also occur between allergen products.
- Do not have unsealed raw materials sitting in warehouse.
Storage – Opened Raw Materials
- Segregation again is key. Follow the same principles as stated in Storage – Warehouse.
- When decanting items into raw materials bins, ensure these bins have lids that effectively seal.
- If decanting a raw material that has a few ingredients, such as chocolate, ensure the label states the allergen. For example, the label may read CHOCOLATE. Beneath it may also read MILK, SOY.
- Use colour coding. Do you already have a colour coding system for religion control or cleaning control? Ensure your colour coding system works for you. The colour coding system may include for the raw material container, the scoop or other tool used to retrieve the raw material, or finished product packaging, etc.
Storage – Work In Progress | Cooling | Packing | Finished Product
- Segregation again is key.
- Ensure the product is clearly labelled or easily identifiable.
- Your staff should know which allergens are attached to which manufacturing product.
- For finished product storage, follow the same principles as Storage – Warehouse.
- Ensure staff only use raw materials as required.
- Always put raw materials back in their correct location.
- When using raw materials, always use care – no big splashes or spillages that may cross contaminate neighbouring items such as other raw materials or equipment.
- Consider a production schedule that is allergen specific.
- For example, if all manufactured finished products have flour, but one product also includes soy flour, then consider this soy flour product to be produced at the end of day or shift.
- Limited with your production schedule? Then ensure effective cleaning and sanitising of your equipment and tools.
- Processing aids used must also be considered for a potential allergen cross contamination. Using canola oil as a lubricant in an otherwise soy-free product? Consider changing to a soy-free lubricant.
- To determine the effectiveness of your cleaning processes, swabs can be purchased to test potential food protein residue left on cleaned equipment and tools. These tests can be conducted in-house or through your NATA-accredited laboratory approved supplier.
- If possible, consider dedicating one or more of the following to prevent cross contamination of allergen to non-allergen finished product:
- A room or area dedicated to allergen or non-allergen product;
- Equipment or tools (this would be more effective if also colour coded or signage is used);
- Production on a particular day of the week or a specific time each day.
- Ensure process flow within HACCP plans is actively adhered to.
- Re-work: caution required to ensure leftover work from a finished product with allergens is not transferred to another product without allergens.
- Work in progress: again, ensure process flow is adhered to.
Maintenance, Cleaning, Sanitising
- Training: ensure staff have received effective training on proper maintenance and cleaning and sanitising of equipment.
- Staff knowledge: staff are required to understand equipment functionality to ensure effective maintenance, cleaning and sanitising.
- Ensure equipment, containers, tools etc are able to be effectively cleaned: no damages such as cracks, melted plastic, and no band-aid solutions such as tape or elastic bands.
- As food proteins can become difficult to remove during the cleaning and sanitising process, consider environment swabbing to verify the effectiveness of the cleaning practices.
- Alongside a regular cleaning schedule, ensure there is a documented cross contamination cleaning schedule.
Finished Product Labelling and Specification
- Should a supplier alter a recipe to a raw material and add or remove an allergen, ensure this change is addressed as quickly as possible.
- The above principle also applies to production should there be a change to standing recipe where an allergen is added or removed, which with affect the finished product.
- How quickly can your product specifications be updated?
- How quickly can your labelling be updated?
- Should sticker labels be introduced for current (incorrect) packaging labels whilst you wait for the updated labels to be printed?
- If using sticker labels, ensure they effectively stick onto finished product with no potential tampering or accidental removal.
- Ensure there is a documented procedure and system in place to check supplier labelling and production recipe to ensure the labelling of your finished product is accurate.
- Train, train, train. And then train some more. Document this training. Ensure refresher training each year. Staff not getting it? Retrain, re-train, re-train or performance manage. Make sure staff are aware of the consequences of a potential allergen cross contamination.
- Test your staff every now and then – can they mention all declared allergens? What are the allergens for your facility? Are there different allergens for different finished product? Do your staff know which allergen attached to which product? And just as important: do your staff know what to do if they identified a cross contamination? What if crushed peanut was added to the recipe instead of crushed hazelnut?
- Ensure staff practice effective personal hygiene. Should there be a change of protective clothing (aprons, hair nets, etc) between batches? Are staff washing their hands, wrists and other exposed body parts before handling non-allergen materials or exposed finished products?
- Corrective action policy. Having a corrective action and non-conforming equipment/product policy is integral… make sure your staff are confident in following these policies.
- Your entire allergen management and control system can fall apart if your staff do not know their allergens or know what to do.
- When mistakes occur – and they will – ensure the issue, corrective action, and preventive control is communicated to all staff. Communication is key for continuous improvement. If possible, have the staff member who made the error rectify the issue – practice makes perfect.
- Staff meals. Dependant on the type of product you produce and the allergen declarations you have made on your finished product packaging, product specification or website, you may consider types of allergens your staff are not permitted to bring from home for their personal meals.
- For example, if you have declared your business to be a peanut-free environment, consider preventing your staff bringing to work peanut-based products.
- Remember, if the owners of the business take allergen management and control seriously, your staff will too.
LoG | Letter of Guarantee
- A Letter of Guarantee is a document that provides details of components that are used in the areas of food processing, handling, and storage. Some information that a LoG may contain:
- Manufacturer’s details
- Finished product details that form part of the guarantee
- A statement that the product is safe and that effective controls are in place to ensure no cross contamination of allergens
- Date and signature of an official of the manufacturer
- A LoG should be able to support the hazards identified and controlled within the HACCP plans.
- A LoG may be sent to customers, patrons, or attached to each product included in the LoG document.
- Some suppliers may be able to provide a Letter of Guarantee.
- Consider a Letter of Guarantee for your own finished products.
What to include? Consider the following elements:
- Allergens declared in your business.
- Approved supplier program and raw material monitoring.
- Australian-declared allergens (and that of all countries your finished product is exported to).
- Control measures in place for receival, storage, production, packing, labelling, despatch, transport.
- Corrective action procedure.
- Definition of allergen and anaphylaxis reactions.
- Due diligence towards allergen management and control.
- If all products vary, allergens attached to which finished product.
- Letters of guarantee.
- Non-conforming product or equipment procedure.
- Open communication, particularly with observations or concerns.
- Personnel hygiene practices.
- Reasoning behind production schedule (if developed due to allergen control).
- Your documented allergen management and control procedures.