Best Practices in Allergen

Management
Jennifer McCreary, Technical Manager,
Training and Education Services
NSF-GFTC/NSF International

www.ifsqn.com
 Who is NSF-GFTC?

• Trainers
• Food safety and quality management consultants
• Scientists and research professionals
• Packaging, labelling and technical experts
• Third Party Auditors (NSF International Certification Body)
 Program Outline
1. How to conduct an allergen risk assessment
2. How to develop and implement your allergen
management plan
Allergen Risk Assessment
 Allergic Reaction
• An adverse immune response following repeated contact with
otherwise harmless substances such as pollens, molds, foods,
or drugs.
 Before Setting Up an Allergen Management
Program Remember:
• Protein component of the food is
the problem
• Allergens that are unidentified
pose the biggest threat
 Purpose of Allergen Risk Assessment
• Determine risks due to unintentional presence of allergens
 Allergen Risk Assessment: Steps
Step 1
• Identify whether the ingredient/product intentionally contains
an allergenic foodstuff
CFIA’s Allergen Checklist
 CFIA’s Allergen Checklist

http://www.inspection.gc.ca/food/non-federally-registered/safe-food-production/allergen-
risks/eng/1357659722449/1357665699917
 Allergen Risk Assessment: Steps
Step 2
• Whether any of these allergenic ingredients have the potential to
cross contact:
– Either foods produced on the premises, or ingredients
– Coming into the premises
 Risk Assessment Outcome: Example
• Risk arising from agricultural contamination
– Carrots are grown in an area where peanuts are also grown as a
commodity crop
 Risk Assessment Outcome: Example
Situation Risk/ Hazard Risk Output from Outcome
Assessment Risk
Assessment

Carrots are Peanuts were Post harvest, After the Major

grown in an grown the carrots go processing Avoidable
area where season before through steps, the allergen
peanuts are in the same numerous likelihood of How?
also grown as a field. Peanut processing contamination
commodity crop contamination steps: is probable
in carrots Scaling,
washing and
scrubbing but
have had
occurrences
where peanuts/
peanut shells
found in the
carrot
Allergen Identification and Mapping
 Allergen Identification
Assessing Recipes/ Formulas and Raw Materials
• Identify and list sources in facility
– Identify ingredients that contain and may contain allergens
– Consider primary and secondary ingredients (spices, colours
and flavours etc.)
• Use master list of all ingredients in facility
 Ingredient Allergen Identification Form
Ingredient Peanuts Tree Nuts Sesame Milk Eggs Fish Crustacea Soy Wheat Mustard
ns

List all ingredients and raw materials at your facility

Indicate the presence of ingredients containing allergens from each category with a simple checkmark.
 Finished Product/ Formula Allergen
Identification Form
Finished Peanuts Tree Nuts Sesame Milk Eggs Fish Crustacea Soy Wheat Mustard
Product/ ns
Formula

List all products currently in production at your facility

Indicate the presence of ingredients containing allergens from each category with a simple checkmark
 Allergen Mapping
• Identifying and highlighting areas and processes where both
allergen and non-allergen products are handled and a chance
of cross contact exists
Process Flow Allergen Mapping-Example
Milk
Processing

Line 1: Line 2:
Plain Salmon
Cream Cottage
Cheese Cheese
Shipping
Packing,
Labelling

Metal Carton
Detector Packing
 Allergen Mapping for Multifacility Operation
Plant A Plant B Plant C Plant D

Peanuts

Tree Nuts


Sesame

Milk




Eggs


Fish

Crustaceans

Soy

Wheat

Mustard

Sulphites
Allergen Management Program
 Allergen Control
Allergens

Deliberate Inadvertent
(Ingredients) (cross
contamination)

Allergen Risk
Labelling
Mgmt

Formulation, Risk Assessment

Traceability

Integrated Allergen
Management Program
 Raw Materials and Supply Chain
• Ingredient purchasing policy with special reference to
allergy status
• Change in supplier must be accompanied by
appropriate checks
• Awareness of allergen status back through the supply
chain
 Receiving and Storage
• Review labels of incoming
products each shipment to catch
any changes
• Separate allergen containing
materials using numbering
system, color coding or tagging
• Ensure handling of allergenic
ingredients does not cause
contamination of other
ingredients
 Storage Segregation Practices
• Segregated storage areas
marked and identified clearly
• Set up allergen zones for raw
and finished products
• No open allergen ingredient
storage
• Dedicated storage containers
• Spillage procedure
 Production Scheduling

• Segregation of allergenic products possible through

product scheduling
• Mostly allergen free products first and the allergenic
products last or
• Ensure a complete allergen clean at the end of an
allergen production run
 Rework/Reuse
• Use color-coded or numbered tags to identify and
record:
– When reworked products with allergenic ingredients are
produced
– Where these products are stored
– The products into which they are reworked
• Use rework containing unique allergenic foods only in
a similar formulation – “identical into identical”
 Personnel Practices

• Separate personnel working on allergenic and non-

allergenic lines
• Identify restricted employees
• Dedicated maintenance tools
• Follow GMP protocols for personal hygiene,
handwashing, eating areas etc.
 Staff Training and Education
• General training on allergen awareness and control at all
levels
• Specific documented training to employees

phharcenv.com
 Design of Premises and Equipment

• Design to allow for appropriate GMPs, changeover

regimes and inspection
• Cleanability
• Easy to access and dismantle equipment
• No crossovers of open production lines
• Ventilation and dust extraction units
• Uncleanable parts of shared equipment- disposable
• Review for new installations and upgrades
Product Development and Brand Extensions

www.vt.edu

• Avoid introducing a new

allergen if possible
• Clearly label new products if
they contain allergens
• Communicate to all
concerned about the new
allergen
 Packaging and Labelling

• Label approval process

• If new package is to be used
due to change in allergen
status, destroy old packaging
to avoid being used in error
• Proper inventory control
procedures for packaging
materials
 Precautionary Labelling

Precautionary labelling not used in lieu of GMPs.

Allergen Cleaning and Validation
 Allergen Clean
• All food contact surfaces are visibly clean. NO visible build up
or residue remains or is allowed to re-contaminate
• Areas around or above the product zones must be free of
allergen containing product or dust (e.g. ledges, overhead
pipes, splash zones, etc.)
 Allergen Cleaning
• Dedicated cleaning equipment
• Effective cleaning equipment and
supplies
• Flushing/product purge
 Allergen Cleaning: Documentation

Allergen Changeover Grid/Matrix

• Identifies which products can be produced
without a wash down and which products
require an allergen clean between their
production
 Allergen Matrix/Changeover Grid

Peanuts

Tree nuts

Egg

Milk

Fish

Crustaceans

Sesame

Soya

Wheat

Celery

Mustard

Sulphites
Product A

Product B

Product C

Product D

Product E
 Allergen Matrix/Changeover Grid
Product Summary of Production Runs and Cleaning Requirements

Product E
A

Product EW
B

Product E WM
C

Product EWMT
D
Allergen
Product EMS Wash
E

E – Eggs; W – Wheat; M – Milk; T – Tree nuts; S - Soy

Allergen Matrix/Changeover Grid

White Milk Chocolate Milk Egg Nog

White Milk Flush Line Colour Wash

Chocolate Milk Colour Wash Colour Wash

Egg Nog Allergen Wash Allergen Wash

 Allergen Cleaning Validation
• Two step approach
1. Physical/visual validation
of allergen change over
2. Analytical validation of
allergens using allergen
test kits
 Testing Protocol

Product Swab Clean Clean Swab

Run Swab
line/equipme Swab
Run product surface(s)
nt with surface(s)
with allergen before
established after cleaning
cleaning
method

Test for
allergen in
question
 Allergen Management Program Review:
System Health Check
• Review and verify allergen hazard
analysis and management
• Product and ingredient
specifications
• Operating procedures
• Cleaning procedures
• Training records
• Analysis of customer complaints
 Questions?

Jennifer McCreary
Technical Manager, Training and Education
NSF-GFTC/NSF International
jmccreary@nsf.org