The presence of undeclared allergens and allergen cross contamination is the leading cause of recalls in Canada.
This subject flows through all of the other sections identified from whether the ingredients are selected from a reputable supplier with food safety protocols identifying allergens, the transportation that can negatively impact the status if segregation and careful protection is not provided. Similarly, when ingredients or other materials are stored with items that contain allergens and they are not effectively identified, segregated, or even known to HUB Users or other people working in the same facility, unintended adulteration of everyone’s products can occur.
Improper or incomplete cleaning and sanitation activities also increase the potential for cross-contamination of allergens as well as increasing food safety risks of the finished products. This also applies to equipment that is not effectively cleaned, particularly after the equipment has been out of commission for repairs and not inspected for residual repair materials or debris. The equipment should also be cleaned prior to repair to ensure that residue from the last production is eliminated.
Incorrect labelling of final products can lead to allergic reactions from those who inadvertently consume a product that contains an allergen whether present due to intention, or through cross contamination of the common surface or through other ingredients.
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> Standard Operating Procedures
> Work Instructions
Challenges, expectations and responsibilities
Challenges, expectations and responsibilities
Knowledge of the priority food allergens and the methods of intentional and unintentional inclusion in a food product is critical for all HUB Users of a Food Hub to understand thoroughly.
Training and knowledge are vital for all HUB Users to minimize allergen risk including what methods to notify consumers with accurate labelling, and Health Authorities in the event the label is incorrect, or an unintentional allergen has been incorporated into the final product and was not included on the label.
Knowledge of suppliers, their methods of transporting ingredients and materials to the facility and ensuring that ingredients or equipment brought from home also do not have allergens unintentionally adhering to these items.
Advising the HUB Management when including allergens within your products so a listing of allergens within the facility can be updated for all HUB Users’ knowledge provided by the HUB Management.
The Allergen Control Program that is developed will include all potential sources, some of which are identified above as well as the methods of reducing and mitigating the risk of unknown allergens being present in the facility.
Good sanitation practices are critical to ensure a successful Allergen Control Program.
As part of the regulated food safety plan, processors must have a list of incoming ingredients. This listing shall include a list of allergens used and processors should report priority allergens that are included in their products to the HUB owner.
Challenges include ingredient sharing, cost of testing, and communicating changes immediately as they occur. Cleaning and storage protocols to reduce cross contamination and security of storage to prevent unintentional contamination must be included in food safety and operational protocols of all Food Hubs.
Ingredient sharing should be discouraged if allergens are present in the ingredients and particularly if another HUB User is stating the lack of all or specific allergens in the products. If shared, the knowledge of allergens must be shared with the HUB User so appropriate relabeling or the decision not to use the ingredient can be made.
HUB Users require notice of allergens that are contained or used within their products or at their stations and what the cleaning steps and proof of the steps being taken to eliminate the cross- contamination potential. The proof may require the increase cost to verify the absence of allergens through testing which can become costly if multiple allergens may be contained within the products. Swabbing test kits may also be required to verify the efficacy of sanitation activities.
Allergen Management Guidelines (November 2022)
Food Allergy Canada has released the Allergen Management Guidelines for Food Manufacturers, in support of support Canada’s 13,000 plus food and beverage manufacturers in managing allergens in their facility and enabling safe options for consumers with food allergy. The guidelines provide a framework for Canadian food and beverage manufacturers on how to develop an allergen control plan or assess their current plan within their facility. The guidelines also include recommendations on the use of precautionary allergen labelling to ensure it can be used as an effective risk communication tool. To download the Allergen Management Guidelines and review the related resources, visit the Food Allergy Canada website.
The documents below are for your HUB use. You may use them as complete (pdf) or modify them to suit your needs as required (Word, Excel or PowerPoint).
Standard Operating Procedures
Allergen Control SOP pdf
List of Priority Allergens pdf
Allergen Checklist pdf
Formulation Template pdf
Product Development and Labelling Allergen Control Program pdf