Lesson 4: Managing Production With Allergens
Equipment Cleaning: A Potential Preventive Control for Allergens
- Thorough cleaning between products with different allergens is required to prevent cross-contact.
- Validation of allergen cleaning procedures is NOT required but may be useful.
- Optional – dedicate tools, surfaces, and other devices for specific allergens.
Allergen Preventive Controls Requirements
- Preventing allergen cross-contact
- Clean shared equipment – potential sanitation controls
- Properly manage rework
- Avoid in-process or post-process allergen cross-contact
- Accurate allergen labeling of finished food
- Ensure labels are correct – potential supply-chain program
- Ensure the correct label or package is used
Training Considerations
Allergen training is critical to implementation and execution of an allergen control plan.
- Applies to a variety of personnel.
- Education and knowledge building is critical.
- Empower individual role and responsibility.
- Reinforce commitment to food safety.
- Highlight changes or new development.
- Human error can be involved – training is essential, as is understanding why allergen cross-contact prevention is critical.
Allergen Cross-Contact Prevention Considerations
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Verification of Allergen Cleaning
- Visually Clean
- Minimum requirement
- No residue, films or sheen
- Optional Tests
- Non-specific tests, e.g. ATP and protein
- May not be sensitive enough to detect some allergens
- Allergen test kits
- Follow manufacturer’s instructions
- Complex tests
- For special situations
- Non-specific tests, e.g. ATP and protein
Clean Break and Lot Control for Allergen Control
- This is an important principle that is critical
- Foundation of clean break and lot control in the meat processing industry particularly for ground beef and RTE products
- Have a clear definition of what constitutes a ‘lot’
- Sanitation is a way to break ‘lots’
- Validated clean break separation/sanitation between lots
- No co-mingling of lots within or between production periods, shifts, or days
- Tools to limit liability and minimize the extent of any recall
- Potential area of weakness for the product industry
- 1 day = 1 lot
- Carryover of product from day to day
- Co-mingling of product between packing lines
Clean Break and Lot Control
- Have to validate when the process changes, not just the product
- Need extended run validation
- Swab at some frequency during the run
- Need to demonstrate that no contaminants/risk/allergens have been introduced during the run
Sanitation Program for Allergens
A successful sanitation program requires:
- Commitment from ownership and management – from the ‘C’ suite down
- None of this will be a success if management is not involved
- Engagement of all departments – Sanitation, Maintenance, QA/QC, Operations
- Everyone needs to work as a team
- A cleanable plant and cleanable equipment – sanitary design
- An operational cleaning and sanitation program
- Adequate numbers of properly supervised trained personnel
- Adequate supply of potable water, suitable and functioning sanitation equipment
- Effective cleaning and sanitation products
- Ongoing employee training in sanitation and safety
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Key Takeaways
- Allergens – The FDA recognizes 9 allergens, other countries recognize more.
- Ingredient Control – Controlling ingredients from the moment they arrive at the production facility is key to food safety.
- Allergen Labeling – Labeling must be done correctly to protect consumers and the company.
- Managing Production with Allergens – Careful and purposeful design of the production process greatly reduces the risk of cross-contact.