Verify Label Accuracy
Raw ingredient labels should be verified with the formulation, and ingredients checked as they are added to the production batch. Procedures to verify label accuracy need to be implemented.
Raw ingredients used in a formulation are compared to the finished product label.
Many companies use private consultants to develop labels.
Most firms discard old labels after formulation changes.
Practices utilised by companies to insure label accuracy varied include checking off ingredients as they were added to the production batch.
An ingredient matrix is utilised to schedule product runs. To alert employees of the risk of allergens, put warning labels on bulk allergen ingredients or colour-coded bins.
In an ideal situation there would not be rework or re-feed. Procedures for handling rework by industry varies. Some have documented procedures for handling rework. They could include: "like-into-like" procedures, no reworked product, which contained nuts or use colour tags, containers and bar coding to document and track how the rework was eventually used.
Push-through is a common method utilized in ice cream batch change over. Product is run through the line until colour changes or designated volume of product has been "pushed through."
Procedures to Prevent Cross-Contamination
Product changeover presents an unintentional opportunity for product that contains an allergen to contaminate a product that does not contain that particular allergen, thus resulting in an undeclared allergen. Equipment cleaning is a critical allergen control point for the production of a non-allergen-containing product following product changeover. All visible and non-visible product residues should be removed from product contact surfaces and areas above exposed product zones. Clean up and sanitation steps should be verified and proven effective.
Companies should use analytical testing as a method to verify that cleaning and sanitation procedures were proven and effective.
In some companies, common utensils are used in production of allergen and non-allergen containing products; however others use separate utensils, mixers and equipment to prevent cross contamination. Cross-contamination can occurr when baking sheets are reused without cleaning, or when baking parchments are reused.
Production is frequently not scheduled or sequenced for allergen control. Bakeries would schedule production "First-in / First-out" or based on product color. For example, sugar cookies would be the first product manufactured followed by various flavored chip cookies, peanut butter finally ending the production run with gingersnaps. Many firms do not have dedicated equipment for allergen and non-allergen product lines. Non-dedicated product lines may be observed to be inadequately cleaned between products, rinsing equipment with water alone or only cleaning equipment at the end of the production day.
One method used to prevent cross contamination of non-allergen and allergen products was scheduling. Production was segregated so that allergen containing products were produced on a separate day of the week than a non-allergen-containing products. Other companies run peanut containing products at the end of the week or the end of the last production shift. Equipment is then completely torn down and cleaned. Cleaning documentation is reviewed and verified prior to the start up of non-allergen products.
Employee awareness and training are the best defenses against unintentional allergen residues being added to products, and so it is important that personnel are trained and dedicated to allergen control.
Sample selection should be based on predetermined sampling plans. If a product contains an ingredient that is not declared on the label a sample is obtained. If a non-allergen-containing product is produced after an allergen-containing product, a sample is obtained. Or, if a change over has occurred where there is limited or no cleaning between products, a sample is obtained. Samples are obtained from the first production batch following any objectionable observation.
The sampling goal is to assist companies in defining critical control points in their process. Facility deficiencies are identified. If equipment had cracks or pits, or otherwise did not appear easily cleanable, a sample is obtained.
Arrow Scientific provides a wide range of allergen kits.
Like any testing sample preparation is important. Each sample may be composited in 10 eight-ounce sub-samples.
Samples are homogenized using a "Robo Coup," and three 500-gram aliquots are reserved (labeled A, B, C). The "A" sample are used for the initial analysis. If the result from this sample is negative, the final result is negative. If the "A" sample is positive, a second chemist preforms the analysis on the "B" sample. If the result from the "B" sample is negative, the final result is negative. If the "B" sample is positive, the final result is determined to be positive. The "C" sample is reserved for further independent testing.
Industry awareness is essential in the control of potential allergen residue risk. Undeclared allergen residues can be introduced during all phases of production. Special emphasis should be placed on assessing raw materials, production scheduling, equipment design, use of rework, sanitation and in packaging and labeling. An allergen prevention plan must determine potential sources of contaminating allergens and identify appropriate controls to prevent their introduction into food products. These controls may include scheduling production of allergen-containing products at the end of manufacturing runs, appropriate labeling and proper use of rework, equipment and system-design considerations, and thorough cleaning of lines after running allergen containing food products. Proper labeling of food products, effective management of label inventories, control of ingredients from suppliers and training of employees are key factors in allergen controls.