“Your site and physicalcontrols and management of allergens”Anton AlldrickSpecial Projects Manager, Science Division

‘Food allergen’ related alerts in UK (2012)

HACCPHazard A system whichAnalysis identifies,and evaluates, andCritical controlsControl hazards which are significantPoint for food safety

(Reference: Codex Alimentarius Food Hygiene Basic Text, 2009)

Prerequisite programmes

• Provide basic environmental and operating conditions to cover 3 key areas: Premises, Personnel, Product

• Alternatively referred to as Good Hygiene Practice and/or Good Manufacturing Practice

• Underpin the HACCP system

• Must be in place and fully operational

• Required for the production of safe, wholesome food

CCP or PRP?Microbiological hazard (1)

CCP or PRP?Microbiological hazard (2)

Microbiological kill:Time x temperature

CCP or PRP?Microbiological hazard (3)

Microbiological kill:Time x temperature

= CCP

CCP or PRP?Food allergen hazard (1)

CCP or PRP?Food allergen hazard (2)

CCP or PRP?Food allergen hazard (3)

Pre-requisite programmes

Hazard Identification

Inadvertent Consumption of a Food Allergen by a Sensitive Individual.

Key Elements of Allergen Management

People Ingredients Process Enforcement

Manager

Key Elements of Allergen Management

• People– Training, protective clothing, staff allocation, staff meals;

agency & contract workers• Ingredients

– Risk assessment, rework, storage & handling, SQA• Process

– Hygiene, packaging, plant lay-out, production scheduling• Enforcement

– Monitoring & Verification– Crisis management

Managing Allergens: Helps & Hindrances

Points to Be Addressed (1)Poor Communication (People)

ENSURE

• ALL personnel are allergen aware

• ALL personnel have sufficient knowledge to appreciate challenges presented by food allergy

– This includes: Production Hygiene QualityMarketing Accounts NPD

In fact EVERYONE

Points to Be Addressed (2)Inadequate Labelling/Poor Information

• Ingredients– Supplier quality assurance– What kind of allergen hazard?

• Product– Does the information on the wrapper reflect the

reality of the manufacturing unit?

Points to Be Addressed (3)GMP

• Hygiene & Plant Design – How well is my equipment/factory understood?

• equipment design• ingredient & product flow

• Storage & Ingredient Handling– What are the opportunities for cross

contamination?• dedicated storage & handling facilities • spill minimisation & clean up

Points to Be Addressed (4)GMP (contd.)

• Rework– management (matrix, storage, control)

• Scheduling– production transfer– production sequence– sanitation

• NPD– do NPD & marketing know what they are doing?

Major Causes of Food Allergy Incidents

• Poor Communication

• Inadequate labelling/poor information :– Ingredients– Products

• Cross Contamination– Hygiene/Plant Design– Rework– Storage– Scheduling– Product Devpt.

HACCP/Pre-requisite Programme Failure

Failure to Consider

Managing food-allergen safety often requires innovative/holistic approaches!

HACCP Principle 6

Establish procedures for verification to confirmthat the HACCP is working effectively, which may include appropriate supplementary tests, together with a review.

Validation Verification

Review

Consumer information: the last line of defence for the food-allergy sufferer

Key Learning

If the hazard is:

Inadvertent Consumption of a Food Allergen by a Sensitive Individual;

does the information provided reflect the reality?