HACCP and Allergy

Mention HACCP (Hazard Analysis and Critical Control Point - pronounced ‘Hassup’) to anyone in the food industry, and they will know exactly what you mean.

For the layman, it is the management system that the food industry uses to ensure that the foods which we pile into our shopping trolleys are safe. However, properly used, HACCP should also be able to ensure that the food that arrives in our trolleys is allergen free.

Following on from our look at the new allergen labelling (see following article), and as part of our plan to help allergy sufferers understand how the food industry deals with allergy, we sent Frances Dale to Leatherhead International last month to sit in on a seminar in which Dr Peter Wareing described how HACCP can be used to control allergens.

HACCP is a pro-active safety management system, which is not reliant on testing the finished food product. It was developed in the 1960s in the US for use in the space industry.

The System
The principles on which the system is organised are as follows:
1. Identify any possible hazards (including potential allergens) and the measures which could be used to control them.
2. Establish the ‘critical control points’ - the points in the operation where risk and hazard occur.
3. Establish ‘critical limits’ - the amount of a contaminant, a bug or bacteria which are acceptable. In the case of allergens the critical limit should be zero.
4. Establish a system by which the ‘critical control points’ can be monitored.
5. Devise a course of action which can be followed to correct any problems.
6. Establish procedures to verify all the above actions
7. Establish a system of documentation and record keeping through which the system can be monitored and regulated.

What is needed to implement it?
For it to be possible to set up such a system the factory must already have and/or use:
1. Standard sanitary operating procedures
2. Good manufacturing practices
3. Pest control
4. Chemical control
5. A system by which they can trace and recall products.
6. A system to deal with customer complaints.
7. A system for controlling allergenic material.

What are allergens?
For the purposes of a manufacturer an allergen is a ‘chemical hazard’ - along with naturally occurring
mycotoxins (toxins produced by fungi or moulds), intentionally added preservatives and unintentionally added agricultural
chemicals, sanitizers or lubricants.

It is, of course, the protein within the food that is allergenic.Of the 12 major allergens (see page one) it is the top eight (peanuts, tree nuts, dairy, eggs, soyabean products, wheat , fish and shellfish) which account for 90% of serious reactions.

Allergen control
In a factory allergens need to be controlled at three main points:
• Recipe formulation
• Where and when the raw materials arrive
• The processing of the food.

The factory needs to:
1. Have tight control over the formulation of the recipe and the ingredients, especially if ‘rework’ is being used. (‘Rework’ is when there is ingredient left over after the first manufacturing run which is ‘reworked’ into another run of what may be a different product. This is very common in, for example, chocolate and confectionery manufacture.)
2. Ensure that allergen and allergen free ingredients are kept in separate containers, use separate utensils and are worked by separate people
3. Clean and disinfect a line after an allergen is run on that line
4. Regularly inspect all equipment for allergen build up and ensure regular dust collection.
5. Confirm that the label is correctly set up and that it matches the product for which it is being produced.
6. Set up comprehensive monitoring, documentation and corrective action should an allergen be discovered.

Raw materials
Identification

• Simple ingredients such as eggs, milk or peanuts are relatively easy to recognise.
• The factory needs to ensure that operatives recognise whey or casein as being dairy products, hydrolysed vegetable protein as soya etc.
• Operatives also need to know the components of compound ingredients (mixes, seasonings or flavourings) and to be able to recognise hidden ingredients such as carriers for seasonings, the protein content of starches etc.
• To achieve this they need good documentation at the receiving point but they also need to have information on the ingredients and possible contamination levels from their suppliers.
This is not easy to achieve as many suppliers are abroad so the factory needs to rely on a third party to assess and evaluate the supplier and their controls.

Receiving and storing raw materials
• There needs to be tight control of delivery vehicles as allergen contamination within a vehicle can bring that allergen into a warehouse.
• All ingredients therefore need to be inspected on arrival and colour coded for storage. ‘Like’ should always be stored above ‘like’ and allergens should always be stored on the bottom layer so that they cannot ‘drop down’ onto other ingredients.
• Ideally allergens should be stored in a physically separate area from non-allergenic ingredients. However, this may not be necessary if the sanitation programme is sufficiently thorough.
• All ingredients need to be check for broken bags.

Formula or recipe design & control
• Formulas or recipes should be devised to exclude all allergens which are not strictly necessary to the recipe.
• All research and development should take place in a dedicated kitchen, so as to avoid contamination on the production lines.
• Once an ingredient is out of its original pack it is impossible to identify it so it is extremely important that the formula or recipe control is very tight.
• All ingredients need to have a dedicated lot number and ingredient code.
• Containers and utensils for allergenic and non allergenic ingredients should be colour coded.
• Where possible there should be dedicated process lines for allergenic and non allergenic products.
• Where allergens are used they should be introduced to the recipes as late as possible to minimise the risk of them contaminating anything else in the factory.

Scheduling
• Allergy free products should always be manufactured before ones containing allergens.
• The longer the run the fewer the changeovers and the less cleaning - so the less chance of an allergen not being fully eliminated.
• An allergy containing line should always be scheduled for the last run before a major clean down.
• New product development (which often contains allergens as the new dishes are still in the development stage) should always be run last before a major clean down.

Product and air flow
• Product flow should be designed to eliminate or minimise cross-over points where contamination could occur.
• Fan placement and air flow should also be designed to draw all allergenic dust straight out of the factory, not across other lines.

Packaging
• Close control must be kept over labelling to ensure that the correct labels go on the correct foods. Most errors occur when there is a roll change in the middle of a run.
• Old packaging should be discarded as soon as it becomes obsolete.

Cleaning
• Factories should be designed for easy cleaning, eliminating ‘dead’ and ‘rough’ areas.
• Written procedures should be developed to identify all areas needing cleaning and how they should be cleaned (wet or dry cleaning).
• Wet cleaning should be used where ever allergens are involved as dry cleaning always risks the spread of allergenic dust.
Disadvantages of wet cleaning are that power hoses merely move dirt around, and that it can lead to mould problems.General

However, for all of these controls to work they will require regular internal and third party audits, good management control and above all else, employee awareness of the dangers that allergens present.

Leatherhead International www.leatherheadfood.com 01372 376761

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First Published in 2005