Elements of a functioning allergen management concept
According to the international guidelines of trade (BRC, IFS) and as part of sound manufacturing practice, comprehensive allergen management is required as part of the production process. Allergen management serves to reduce the risk of cross contact and the resulting need for trace labelling. Allergen management includes the following essential components:
- supplier survey and assessment of the raw materials supplied
- warehousing
- the route from warehouse to production
- production
- delivery.
In this process, all departments in a production facility must be involved, i.e. not just quality control, but also product development as well as the purchasing and sales departments. The central element is the production itself - with the specification of certain production sequences and cleaning validations.
Products which contain allergens should ideally be produced in such a way that the production sequence is followed by a cleaning step to eliminate the possibility of any carry-over of allergens to the next product. Cleaning studies are necessary for the cleaning of a production system following “allergenic production”, and are to be validated in the form of a written report where possible.
The VITAL concept (version 2.0) of the Australian Allergen Bureau has been applied for years by various international producers for assessing the risk of the unintended presence of traces of allergens in foodstuffs (cross contacts) and the trace labelling derived therefrom. As an international allergen centre of excellence, ifp has been a member of the Australian Allergen Bureau (Members of the Allergen Bureau) for many years, and has been approved by the latter as an official training provider for the VITAL 2.0 allergen management concept.
Risk assessment and use of warning notices for labelling allergenic cross contacts as part of allergen management
Current food-related regulatory provisions and laws in Europe, require that allergenic substances be declared. Since 13 December 2014, it has been mandatory in terms of the Food Information Regulation (EU) 1169/2011, specifically Art. 9(1) (C), to label any ingredient or processing aid listed in Annex II or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product - even if in an altered form.
What remains unchanged, however, is the absence of any regulation concerning the labelling of unintentional traces which can enter foodstuffs through cross contact during the production process. Nevertheless, trace labelling is recommended in order to satisfy product liability requirements.