SQF Audit Tip #6 Designing an Effective Allergen Control Strategy

As an SQF consultant, I have helped in the development of many SQF compliant allergen control plans. In the SQF Code Section 2.8.2, there is guidance for comprehensively helping to understand and control the potential hazards of allergen cross-contamination.
The first step to complying with this section of the code is to write a clear procedure. The procedure and included work instructions will detail the programs in place for the specific elements in the section.
Instructions must be written for the process of reviewing raw materials for potential allergen contamination, including indirect additives like non-stick sprays, and lubricants and assigning risk. For example, an almond supplier, who also processes peanuts, is of a higher risk then a supplier that only produces nuts. Then control measures must be developed to reduce the risk and more closely monitor it. The hazards and the controls of each ingredient should be written into a risk analysis for each raw material. The allergen hazard is also a chemical hazard, in the HACCP plans, hazard analysis.
It is required that an allergen register be created. For many processors, it makes sense to post the allergen register in the allergen storage area to reinforce the allergen awareness training and reinforce the handling requirements.
The employees working with allergens must be trained on handling requirements, including written instructions for identifying allergens upon receipt. For example, casein may not be readily identified as milk derived. It is important to make sure that employees properly identify and store it. The storage area must be clearly marked with a tag for the specific allergen designated there. The allergen location would typically only have same-over-same or like-over-like, based on the risk assessment, but a universal best practice for allergen segregation is to have each unique allergen located on the bottom rack.
Where dedicated lines and equipment are not feasible, it is most important to assure that allergens are effectively removed at change-over. The cleaning can be visually monitored to assure effectiveness, but a documented residue testing protocol is typically part of the verification process.
In the section there is also Element 2.8.2.2 requiring the identification of, in accordance with regulatory requirements, the allergens that were made on the same line. While disclaimers like, “may contain…” are common place in labeling, and are part of the code, there are no excuses for cross-contaminating foods with allergens through improper handling or cleaning.
Also in the section is a requirement to take into account the conditions in which a product is produced. So, where non-allergen containing foods are not scheduled before allergen containing foods, it is particularly important the production schedule provides enough detail to investigate instances of potential cross-contamination.
Finally, rework containing allergens must be handled in accordance with the allergen policy and traceability details from the batch of rework must be completely preserved in the finished product.
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