and records of those training sessions
maintained as hard copy and/or as electronic records. In fact, allergen control
reaches beyond production. It should
encompass research and development,
product formulation, and vendor evaluation and approval. Then, once a company has established a network of
vendors, purchasing must buy only from
those operations. Allergen control must
be an integrated system.
Part 1 of this article will discuss research and development, vendor approval and selection (purchasing),
shipping and receiving, warehousing and
human resources. In our subsequent
issue, part 2 will cover production, labeling and sanitation.
“Allergens are serious business in today’s
food processing industry.”
Research and Development
Today, many companies outsource
their product development efforts.
Whether the work is done internally or
outsourced, one of the charges to the
R&D group should be to minimize the
use of potential allergens. This is not to
say that allergens should not be incorporated into products. Product development specialists should take care to
utilize ingredients that do not contain allergens as a minor ingredient. For example, many potential allergens are healthy
ingredients. Soy protein, tree nuts and
certain fish are known to be heart
healthy. The challenge is to minimize
the use of potential allergens. If there is a
choice between using an ingredient that
contains a small amount of allergen and
one that does not, focus on eliminating
the allergen. By doing this upfront, potential risks to consumers and the challenges of monitoring and controlling
allergens in the plant are reduced.
ities. According to Kathy Gombas at
Dean Foods Company, some plants test
incoming bulk tankers for allergens and
have discovered that not all tanker washing facilities are created equal. They
found and rejected tankers that tested
positive for allergens that had supposedly been cleaned.
The vendor quality program should
include protocols for the following:
1. Selection of potential vendors
2. Conduction of a preliminary evalua-
tion of the operation’s technical,
quality and financial capabilities
3. Vendor audits to confirm their capabilities
4. Corrective actions for any deficiencies noted during preliminary evaluations and on-site audits
5. Final approval
6. Performance monitoring
The same criteria should be applied
to current vendors. Ideally, every processor should have detailed files on the capabilities of all vendors and service
providers. These files should flag any
materials that contain allergens or sensitizing agents.
As part of the preliminary evaluation,
many operations demand that potential
and current (including long-time) suppliers fill out a questionnaire about their
operations. This helps to build the vendor database and allows a better understanding of where your ingredients
originate. You may also discover something that needs to be addressed. This
questionnaire should include questions
specific to allergen handling and control
programs. Potential buyers want to know
what allergens are used in the plant, the
control programs and what is done to
verify that cross-contamination is not an
issue. Auditing the facility should be
part of the initial approval process and
an ongoing vendor quality program.
Many operations utilize third-party services for these exercises. However, it is
much better to conduct these audits internally. It lets you know your vendor
much better. There are some large operations that have made business decisions
to audit only those operations with
which they do large volumes of business.
This is a bad idea. Problems can come
from both small and large operations,
and from small and large purchases. The
procedures for selecting and maintaining
the vendor quality program must be
fully documented; such documentation
should clearly state who is responsible
for each phase of the program and actions to be taken if there are deviations
or failures to meet established standards.
Once you are satisfied that the vendor can meet your needs and it is time
to work with purchasing to sign contracts, ask that the supplier clearly mark
all products that contain allergens. Many
companies are currently doing this. I
have had reports from ingredient suppliers that by clearly tagging their cases or
bins with markings such as: “
ALLERGEN” or “ALLERGEN – WHEAT,”
they have been able to increase their
sales. This helps potential users both in
receiving and in their warehouses.
Vendor Approval and Selection
(Purchasing)
Vendor evaluation and approval
could be a complete publication unto itself. When it comes to allergen control,
the program must address not only vendors of raw materials and ingredients but
certain service providers. Specifically,
those companies who buy bulk ingredients, such as milk, spring water, juices,
soy sauce or other materials, must expand their vendor program to include
transport companies and tank wash facil-
Shipping and Receiving
At the plant level, allergen control begins at the receiving docks. The person
or persons who manage receiving should
be provided with a complete list of all
ingredients containing allergens and
what specific allergens are in each of
those products. Purchasing, quality assurance or whomever is designated as
the manager for the vendor quality program must provide receiving with this
list. It is wise to update this list at a regular basis (e.g., quarterly) since materials
are constantly being added and deleted
from the ingredient list. If, as noted
above, suppliers do place allergen tags
on their materials, they help ease the
burden at the receiving docks.
The basics of receiving apply whether
incoming materials are allergenic or allergen free. The receiving crew should first
check seals on containers to ensure that
they match the bill of lading (BOL). If
loads are received as less than loads or
seals are not mandated, they should
check for product damage, ensure that
