17. Process control
Allergen controls
Once the allergen risk assessment has been completed the controls from the assessment must be implemented and effectively managed.
Allergen controls
Once the allergen risk assessment has been completed (see topic 6 contamination control, allergen management for more information) the controls from the assessment must be implemented and effectively managed. This section looks at the specific allergen controls, identified by the standards.
The standards
This article is written to meet the allergen controls in the following clauses of the requirements:
| BRCGS Food Safety Issue 9 | 5.3.4 Cross-contamination procedures |
| BRCGS Packaging Issue 6 | No specific allergen controls specified |
| BRCGS Agents & Brokers Issue 3 | No specific allergen controls specified |
| BRCGS Storage & Distribution Issue 4 | 7.7.2 Allergen management plan |
| FSSC22000 Version 6 | No specific allergen controls specified |
| IFS Food Version 8 | No specific allergen controls specified |
| SQF Edition 9 | 2.8.1.2 – 2.8.1.6 Allergen controls |
| FSMA Preventive controls for human food (Final 2015) | No specific allergen controls specified |
| Additional standards | M&S, AIB |
The requirements
Personal protective clothing (PPC)
Where clothing is identified as a source of allergen contamination, separate PPC should be considered.
Where used, it must be colour coded, so that personnel working in the area can identify when allergenic materials are being handled.
Processing equipment
Where tools and utensils are dedicated for use with allergens, it must be identifiable, using colour coding or labelling.
BRCGS Food Safety Issue 9
There were no changes in Issue 9 that impact the clause in this article.
Customer
This is a general overview of the allergen controls detailed in customer codes of practice; however your business must refer to your customer’s standards to identify the requirements that are applicable.
Personal protective clothing (PPC)
Colour coded PPC isn’t optional with customer standards, it’s a must.
Contingency plans
Where dedicated equipment is used for allergen production, there must be continency plans in place – in case the equipment breaks down or can’t be used.
Processing equipment
This is another example of ‘a must’ rather than a ‘should’. The certification standards state that when utensils and tools are dedicated, they must be colour coded or labelled. Whereas customers state that utensils and tools must be dedicated and therefore they must be colour coded or labelled. Where containing and free from products are being made in the same area, allergen equipment must even be locked away, so that it can’t be used by mistake.
Cleaning validation
The detail required to prove that allergen cleaning is consistently effective is far greater in the customer requirements. They specify when samples must be taken, how many, how often and how they must be tested.
Process control
Pack 17: Process control
This pack gives you a really robust structure to determine what your process controls should be and implement a system which will ensure that non-conforming product doesn’t get sent to the customer.
Plus, it covers pack control and print control. The procedure covers verification of cleanliness and identification of allergenic materials in process specifications or bill of materials. It’s packed full of detail and makes this complicated subject really easy to understand and apply to your business.
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