julia banks shared

Copyright 2014© Food Integrity Consulting Ltd

All rights reserved. No part of the material may be transmitted or reproduced in any form (including photocopying or storage in any medium by electronic means) without the written permission of the copyright owner. Application for permission shall be addressed to

Food Integrity Consulting Ltd, Shenna House, Cockley Road, Farthinghoe, NN13 5PD

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Julia Banks Food Integrity Consulting ltd

www.foodintegrity-consulting.com

QUALITY SUPPORT FOR SUCCESS

HOW TO RISK ASSESS YOUR SITE AND

IMPLEMENT SEGREGATION

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1. HOW to go about allergen risk assessment?

2. WHAT controls should be implemented?

3. HOW to incorporate controls into food safety management systems?

There can be a lack of reliable guidance on both of these aspects.

It can be a challenge to identify BEST PRACTICE

CHALLENGES FOR FOOD PRODUCERS:

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RETAILER and FOOD PRODUCER REQUIREMENTS

• Removal of unnecessary allergens • Clear and legal labelling of the presence of

allergens• ‘May contain’ statements used judiciously• The correct identification and labelling of 'free

from’ products

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CARRYING OUT ALLERGEN RISK ASSESSMENT

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RISK ASSESSMENT CHALLENGES• Allergen risk assessment

can appear over complex

• It is easy to overlook important detail

• It must be systematic - every allergen assessed at every process stage

• Role of HACCP ?

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RISK ASSESSMENTCHALLENGES

This session:

•Will present a practical approach to risk assessment

•Will discuss how to translate this into action

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WHAT DOES THIS THIS METHOD AVCHIEVE?

• Systematic - every allergen is assessed at every process stage

• See the bigger picture and prioritise

• Look at the whole and not just the parts

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RISK ASSESSMENTCHALLENGES

It must be a live system

To enable it to be kept up to date and to challenge / check NPD

NPD TECHNICAL / COMMUNICATION CHANNELS?

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WHO SHOULD TAKE RESPONSIBILITY FOR RISK

ASSESSMENT?

Someone who

understands food allergy

SOMEONE WHO HAS EXCELLENT PRODUCT AND FACTORY FLOOR

KNOWLEDGE

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Raw material and recipe analysis:

•What allergens are being intentionally used on site.•What are the potential raw material cross contamination risks

THE RISK ASSESSMENT PROCESS

KEY STAGE1

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RAW MATERIAL AND RECIPE ANALYSIS

• The risk assessment must provide information on:– Which products are at risk from

allergens intentionally present on site– Precisely what form those allergens

take

– Not just ‘egg’ for example but egg in the form of Lemon curd or meringue.

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DO ALL PRODUCTS CONTAIN THE SAME ALLERGEN?

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ATTENTION TO DETAIL IS KEY

You need to know the names of the ingredients to help with later risk assessment stages

UPC Product

102666Skinny Lemon

Mousse Skimmed milk powder

103666

Skinny Raspberry

Mousse Skimmed milk powder

104666Lemon Swirl

CheesecakeButter (Lemon Curd), Full

Fat Soft Cheese, CreamLemon Curd

Wheatflour (Ginger

Biscuit crumb)

Wheatflour (Biscuit

crumb)

105666Raspberry

PannacottapacCream

106666Chocolate

Mousse

Milk Fat, Whole Milk

Powder , Skimmed milk

powder

SOY LECITHIN

(CHOCOLATE )

107666

Raspberry

Meringue

Milk Protein, Dried

Skimmed Milk,Dried

Whole Milk

(Meringue(White

Chocolate Coating)),

Cream, Skimmed Milk

Meringue (large)

Soya Lecithin

(Meringue

(large)(White

Chocolate Coating))

108666Small Trifle

DessertButter (sponge), Cream Sponge (63 mm disc)

Soya Lecithin (Sponge

63mm)

Wheatflour (Sponge

63mm)Wheatflour (Sponge)

109666

Mandarin

Dessert

Skimmed milk powder

(sponge), Milk Protein ,

Cream, Skimmed Milk

Sponge (apricot

sponge)

Soya Lecithin (Sponge

apricot)Wheatflour (Sponge) Wheatflour (Sponge)

110666

Chocolate

Mousse


Powder , Skimmed milk

powder

Soya Lecithin

111666

Strawberry Trifle Milk Protein , Lactose

(MR05), Butter (Sponge),

Cream, Skimmed Milk

Powder

Sponge (drop sponge) Wheatflour (Sponge) Wheatflour (Sponge)

112666

Choc Muffin

DessertSkimmed Milk powder

(sponge), Milk Fat, Whole

Milk Powder, Skimmed

Milk Powder

Mini muffin

Soya Lecithin)

(Chocolate Curls)

(Cocolate Callets )

Wheatflour (Sponge) Wheatflour (Sponge)

113666Raspberry

PannacottaCream

114666Full Fat Lemon

Mousse

Cream, Milk Protein ,

Skimmed Milk

115666

Full Fat Belgian

Chocolate

Mousse

Cream, Milk Protein

(UNIQFFM1), Dried Whole

Milk (823NVGB), Dried

Skimmed Milk.

Soya Lecithin

(Chocolate 823NVGB)

117666

Full Fat Toffee

Mousse

Cream, Milk Protein

(UNIQFFM1), Dried

Skimmed Milk,

Sweetened Condensed

Skimmed Milk, Unsalted

Butter

Soya Lecithin

(Butterscotch Pieces)

118666

Toffee Muffin

Dessert

Dried Skimmed Milk,

Sweetened Condensed

Skimmed Milk

(Butterscotch

Pieces)(Toffee Sauce),

Unsalted Butter

(Butterscotch Pieces),

Dried Skimmed Milk

(Sponge), Milk Fat

(Sponge), Whole Milk

(Sponge), Dried Whole

Milk (Chocolate Curls).

Toffee Muffin

Soya Lecithin (White

Chocolate Curls)

(Butterscotch Pieces).

Wheatflour, Wheat

Starch (Sponge)Wheatflour (Sponge)

119666Twin-Pack Rice

PuddingClotted Cream, Milk

120666

COU Chocolate

Mousse Single

FTG


Powder (LE321), Skimmed

milk powder

Soya Lecithin (LE321)

121666

Family Mandarin

Dessert

Butter (sponge), Milk

Protein (WFC13), Cream,

Skimmed Milk

Sponge (large)Soya Lecithin (Sponge

large)Wheatflour (Sponge) Wheatflour (Sponge)

MIL

K

WH

EAT

GLU

TEN

EGG

S

SOYA

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POTENTIAL RAW MATERIAL RISKS - CANS OF WORMS MAY BE OPENED…

• Time consuming investigation work required.

• What ingredients is the supplier using? How will you know?

• Are the ingredients used compatible with what you are manufacturing?

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POTENTIAL RAW MATERIAL RISKS

• If allergens are on site - what can be gathered about the controls in place

• What further questions need to be asked?

• Is there a need to audit?

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•Accurately map where allergens and non allergens some into contact

•Clearly show where products and ingredients which do not contain the allergens are at risk

•Problem with some risk assessments – they focus on the allergen rather than the products at risk


KEY STAGE 2

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Can be hard to use HACCP flow charts for this stage of risk assessment:

•Too complicated•End up with too many charts that focus on one group of products alone•Hard to see all the risks at once

Spread sheet based maps preferable, with all areas and risks on one page


KEY STAGE 2

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• Where both allergens and products / ingredients at risk are present assess risks

• Clear criteria must be in place as the basis for risk assessment.

• Allergens don’t jump!• Allergens are not

radioactive!

THE RISK ASSESSMENT PROCESS KEY STAGE 2

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• Summary taken from the Food Standards Agency Voluntary Guidance on Allergen Management and Consumer Information (July 2006) and gives

guidance on the aspects to be considered when carrying out this risk assessment.

As part of this process, identified risks should be classified as either ‘probable’ or ‘remote’ using the criteria described in Table 2 below, as well as any other criteria relevant to the factory.

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THE RISK ASSESSMENT PROCESS KEY STAGE 2 The desk top risk assessment must be verified on the shop floor to :

•Understand what action is required•Seek views from factory floor teams•Understand ‘what good looks like’•Find hidden areas of weakness

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KEY STAGE 3 2 criteria are used to carry out this stage of risk assessment:•the likelihood of the issue occurring, •and the quantity of the allergenic material involved.

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IMPLEMENTING ALLERGEN CONTROLS

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THE ROLE OF GMP• Many allergen controls relate to basic GMP

disciplines• Therefore it is easy to integrate them

within PRP plans• The majority of allergen controls fall within

PRP plans• Some may be OPRP’s

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THE ROLE OF CLEANING

• Is cleaning required for GMP to support allergen management

• Or• Will it play a critical and

fundamental part in achieving safety (if production lines and equipment are not dedicated)?

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CLEANING CHALLENGES

• If the manufacturing process is ‘dry’, and wet cleaning is impractical

• Removing the allergen might be difficult

• Particularly if production equipment is complex, large scale

• Solutions?

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THE ROLE OF CLEANINGRisk assess: to find hard to clean areas in

machinery

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CAN YOU RELY ON CLEANING

Consider - how much supervision will be required to get cleaning right?How much verification will be required?How much are cleaners trusted?

CLEAN LIKE THIS

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CHANGEOVER CLEANING• Risky activity: Time

pressure• Resource issues – how

much supervision will be required?

• Errors could be disastrous.

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RAW MATERIAL STORAGE

• Separate storage bays, dedicated?

• Not a necessity - avoiding miss picks is key- labelling and organisation

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USING ALLERGENIC MATERIALS IN MANUFACTURING

• Controls required unique to each factory

• One size does not fit all

• Use risk assessment to judge

• Validation and verification critical

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• Common practice to use the same production line.

• Is sufficient cleaning resource and time available end of run?

• Production schedules– ALLERGENS LAST – if practical?

• Cleaners trained? Change parts included?• Effective validation and verification

carried out?

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• Allergens last might not be practical.

• And other lines could well be running at risk product.

• Additional controls can be essential.

• Can these be implemented in practical terms?

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THE NPD CHALLENGETechnical department involved at an early stageClear procedures and decision making in place

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PLANNING OF PRODUCTION PROGRAMMES TO MINIMISE

RISK• Planners trained and

understand factory controls• Clear procedures to follow to

make sure production sequences are adhered to?

• What if sequences have to be changed?

• Arguably too much reliance on planning instead of risk assessment and cleaning

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ANY QUESTIONS?

[email protected] 07793 937531


Copyright 2014© Food Integrity Consulting Ltd

All rights reserved. No part of the material may be transmitted or reproduced in any form (including photocopying or storage in any medium by electronic means) without the written permission of the copyright owner. Application for permission shall be addressed to

Food Integrity Consulting Ltd, Shenna House, Cockley Road, Farthinghoe, NN13 5PD

julia banks shared

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