SQF Allergen Management: Strategies for Compliance Success
In 2023, nearly half of all food recalls were due to undisclosed allergens. The SQF Code's allergen management requirements are designed to help you avoid these costly recalls, protect your reputation, and ensure food safety.
To ensure compliance and successful SQF certification, you must understand the specifics of each allergen management requirement. This article will explain the elements of allergen management within the SQF Code, offering guidance on developing an effective allergen control program.
Purpose of SQF Allergen Management Requirements
The allergen management component of the SQF code aims to:
Reduce cross-contamination: Implement measures to prevent allergen cross-contact in the production environment.
Ensure proper labeling: Guarantee that all food products are correctly labeled with allergen information to prevent errors and protect consumers.
Ensure clear traceability: Maintain traceability systems to track allergens from raw materials through to finished products, ensuring quick and accurate recall if necessary.
These allergen management principles apply both to intentionally added allergens (for example, nuts in a nut-based product) and unintentionally added allergens (for example, nut contamination in a nut-free product).
Applicability of SQF Allergen Management Requirements
The SQF allergen management requirements are included in section 2.8.1 of the following SQF Food Safety Codes:
Primary Production
Manufacturing
Packaging
Storage and Distribution
Food Retail
Food Service
Allergen management is also included in the SQF Fundamentals for Manufacturing (Basic and Intermediate). It is not included in the SQF Fundamentals for Primary Production.
Allergen management is also not included in the SQF Quality Code. However, it is related to the Quality Code’s requirements surrounding “Identity Preserved Food,” which sets requirements for the documentation and labeling of foods with “identity-preserved status,” including foods that are “Free from” specific ingredients.
SQF Allergen Management Requirements
The specific requirements for allergen management may vary slightly across different SQF codes, but the basic requirements are similar across each. To see the specific requirements of the code most relevant to you, refer to the SQF Institute Code Selector.
Below are the requirements laid out in the Food Safety Code for Manufacturing, as these are among the most robust.
Allergen Program & Risk Assessment (2.8.1.1):
You need a documented plan outlining how you'll control allergens and prevent contamination. This plan should include:
A risk assessment for all ingredients, processing aids, and lubricants that contain allergens.
An assessment of potential allergen sources in the workplace like lunchrooms, vending machines, and visitors.
A list of allergens relevant to your manufacturing country and destination countries (if known).
An easy-to-access list of allergens for relevant staff.
Details on how allergen hazards are addressed in your food safety plan.
Management plans for controlling identified allergens.
Coordination with suppliers is critical for ensuring food is safe from allergens. Ensure suppliers maintain clear documentation and declare any allergenic substances and potential cross-contact allergens.
2. Staff Training (2.8.1.2):
This section emphasizes staff training to ensure proper handling of allergen-containing products. Provide instructions to all relevant staff on how to identify, handle, store, and segregate raw materials and products containing allergens.
3. Allergen Identification & Segregation (2.8.1.3):
Clear procedures are essential to prevent allergen cross-contamination. This section requires:
Identification Procedures: Establish methods to clearly identify allergen-containing foods.
Segregation Procedures: Implement and continually monitor procedures for segregating allergen-containing foods from non-allergen products.
4. Cleaning & Sanitation for Allergen Control (2.8.1.4 & 2.8.1.5):
These sections focus on cleaning and sanitation practices to minimize allergen risks:
Cleaning Procedures: Establish effective cleaning and sanitation procedures for equipment and areas where allergens are present. These procedures must consider:
Risk Level: The level of risk associated with the allergens being handled.
Legal Requirements: Adherence to all relevant regulations concerning allergen cleaning.
Allergen Removal: Thoroughness to remove all potential allergens, including airborne particles.
Separate Equipment Requirement: When proper cleaning or segregation isn't possible, dedicated handling and production equipment are required for high-risk allergens.
Documentation: Document your cleaning procedures.
Validation: Validate cleaning and sanitation procedures to ensure they effectively remove allergens. Use allergen-specific tests for validation.
5. Product Changeover Procedures (2.8.1.6):
Document and implement product changeover procedures to eliminate the risk of cross-contact where allergenic material may be present. Ensure thorough cleaning and separation during product changeovers to prevent cross-contact, especially for high-risk allergens.
6. Labeling & Traceability for Allergen Control (2.8.1.7 & 2.8.1.8):
Labeling: Ensure clear identification and labeling of products produced on lines and equipment used for allergen-containing foods, in accordance with regulatory requirements.
Traceability: Ensure the traceability system considers the conditions under which allergen-containing foods are manufactured and allows for full traceback of all ingredients and processing aids.
7. Label Accuracy & Finished Product Control (2.8.1.9):
Maintaining accurate allergen information on product labels is essential for consumer safety. This section requires that you implement documented methods to ensure the accuracy of finished product labels regarding allergens. These methods may include:
Label Approval: Approving labels upon receipt.
Label Reconciliation: Reconciling labels during production.
Outdated Label Control: Destroying outdated labels.
Label Verification: Verifying labels on finished products.
Product Changeover Procedures: Implementing product changeover procedures to prevent labeling errors.
8. Reworking Allergen-Containing Products (2.8.1.10):
Establish procedures for re-working products with allergens that ensure product safety and integrity are maintained. Clearly identify and trace reworked products containing allergens.
9. Allergen Management for Sites Without Allergens (2.8.1.11):
Sites that do not handle allergenic materials or produce allergenic products must still document, implement, and maintain an allergen management program to mitigate introduced or unintended allergens through supplier, contract manufacturer, site personnel, and visitor activities.
For more guidance on implementing these requirements in your operations, see the SQF Institute’s Tip Sheet 17 on Allergen Management.
Best Practices for a Robust Allergen Management Program
These are some of the ways a facility can reduce risks:
Reduce Cross-Contact
Beyond rigorous cleaning and sanitation, here are strategies to effectively reduce cross-contact:
Dedicated Production Lines: Use separate production lines for allergen-containing products to prevent cross-contact.
Physical Barriers: Install physical barriers to separate areas where allergen and non-allergen products are processed. This prevents accidental mixing.
Production Scheduling: Schedule the production of allergen-containing foods at the end of the production cycle to minimize the risk of cross-contact with non-allergenic products.
Ensure Proper Labeling
Proper labeling is crucial for consumer safety:
Regular Audits: Conduct regular audits of label design and printing processes to ensure accuracy and compliance with allergen labeling regulations.
Barcode Systems: Use barcode systems to verify that the correct labels are applied to products. This helps prevent labeling errors.
Packaging Checks: Implement rigorous checks during the packaging process to ensure every product is correctly labeled according to its content, preventing mislabeling.
Ensure Clear Traceability
Enhancing traceability is vital for managing allergens:
Advanced Tracking Systems: Implement advanced tracking systems to monitor ingredients from receipt through processing to final distribution. This reduces the time necessary to trace ingredients back to their source and reduces the potential for human errors.
Digital Tools: Use digital tools to record and trace batch numbers and production dates. This improves accuracy and allows for quick identification and recall of products if an allergen contamination occurs.
By adopting these best practices, you can build a robust allergen management program that ensures compliance with the SQF Code, protects consumers, and reduces the risk of costly recalls.
SQF Certification with QIMA/WQS
With over 30 years of experience in the food industry, QIMA/WQS provides SQF certification services for every segment of the food supply chain. Partnering with us streamlines the SQF certification process, enhancing your allergen management and demonstrating your dedication to food safety. Our expertise ensures a smooth and efficient certification journey, supporting you at every step to achieve and maintain SQF compliance.
Contact us to learn more about SQF certification or book an audit today.
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