• Summary;

M&S MANAGEMENT OF FOOD ALLERGENS SECTION A: RISK ASSESSMENT February 2016 v13

M&S 5.3 Raw Materials

  • The allergen status of raw material suppliers must be included as part of the supplier raw material approval process. Where a raw material site handles allergens that are not currently handled on the direct supplier’s site a risk assessment must be carried out and appropriate investigation explored with the direct supplier.

M&S 5.4 Nut and Sesame Control of Raw Materials

  • All raw material suppliers must be asked to complete a questionnaire (which includes a list of ingredients classified as nuts or sesame), confirming whether or not they handle nuts or sesame at any stage. Where nuts and /or sesame is handled at a raw material supplier or it is possible that they could be introduced, it must be ensured that nut and sesame cross contamination risks are satisfactorily controlled, through competent technical audits. Marks and Spencer suppliers must ensure that their raw material suppliers inform them if nuts and/or sesame are to be introduced into their factories or in the case of nut and/or sesame handling raw material suppliers, if there is any change to the level of nut contamination risk.

M&S 6.0 Essential Requirement - Allergen risk assessment

  • The use of risk assessment is paramount in developing policy and resource on an individual basis for each manufacturing site. THE SUPPLIER MUST COMPLETE A FULLY DOCUMENTED ALLERGEN RISK ASSESSMENT. THE USE OF EACH OF THE 5 STEPS DEFINED BELOW IS MANDATORY. TABLES 1 & 2 MUST BE USED FOR RECORDING THE RESULTS OF THE ASSESSMENT (LAYOUT ONLY – SUPPLIER’S OWN COLOUR CODING CAN BE USED). IMPLEMENTATION IN THE FACTORY OF SEGREGATION REQUIREMENTS IS AN ESSENTIAL REQUIREMENT. The site risk assessment must be updated with any new / delisted products for all customers. If a new allergen is introduced onto site or the site allergen status has changed this must be signed off by the M&S lead technologist. If no amends have been made, the site risk assessment must be reviewed at least annually with their M&S technologist and site status reconfirmed.

M&S 6.1 Step 1 – Listing all allergens on site

  • The objective of this first stage of risk assessment is to establish:  Which allergenic materials are handled on site and in what form.  Which products manufactured on site, contain these allergens as an intentional ingredient To achieve this:  All products manufactured on site must be listed (i.e. including non M&S)  Checking every ingredient and sub-ingredient of components, a matrix of which products contain any allergens as an intentional ingredient, must be produced.  Where the product intentionally contains the ingredient, a brief description of the form of the allergen takes must be included.  Results are to be recorded a per Table 1  Results should be able to be filtered by retailer for audit purposes.

M&S 6.2 Step 2 – Detailed assessments by M&S product

  • A detailed assessment of the process flow of every Marks & Spencer product manufactured on site must be carried out. This involves mapping out the flow of ingredients and raw materials, work in progress and finished products from receipt of raw materials through to finished product packing. The objective of this stage of the risk assessment is to establish any risks of contamination from each allergen through every stage of production. From this a detailed map of where allergens have the greatest impact in the factory will be available to aid Allergy Management of a site. This will also aid in generating an accurate Improvement plan for the site. The results of the risk assessment must be documented on Table 2. The Risk Assessment must be carried out following HACCP principles i.e. trained multi-disciplinary team; documented hazard analysis for each stage; all process steps incorporated; desktop assessment followed by factory verification. Identified hazards must be graded as Low, Medium and High. Supporting evidence must be recorded on how the risk has been identified, this information must be auditable. Not applicable or blanks should only be used where an allergen does not enter a specific production area or process. Each M&S product manufactured at site must be assessed against each of the individual allergens handled on site, which are not in the product as an intentional ingredient All risks must be assessed taking into account factory controls that are in place to control allergens on site when operating under normal operating conditions.
    Although every factory and process is different and should be considered on a case by case basis below are some examples of risk grading: LOW:  Allergen is in sealed containers in a dry store, stored in dedicated racking with clear allergen controls and spillage procedures.  Allergen is contained within product which is sealed in finished packaging MEDIUM:  Allergen is used on the same line, although validated cleaning has been carried out to show that residue can be removed  Allergen comes into close proximity to other products but risk is controlled eg: within shared fridges. HIGH:  Allergen is used on the same line / piece of equipment and can’t be cleaned to a satisfactory level.  Allergen can be air borne (powder) and cause risk of contamination to other products.

M&S 6.3 Step 3 – Allergen improvement plan

  • Following completion of the risk assessment, any issues identified for improvement should be included within an Allergen Management Improvement Plan. This plan is to be agreed with the M&S Technologist. This plan should be based on the defined requirements in Section B and each action designed to lower the cross contamination risks identified through the Risk Assessment (Step 2). The plan should be prioritised with the ‘High’ risks as the highest priority for action and clear timescales agreed. This Improvement Plan should be a live document with site allergen controls constantly being challenged.

M&S 6.5 Step 5a – Overall factory grading

M&S 6.4 Step 4 – Use of alibi labeling decision tree

  • Following completion of the Risk Assessment Step 2 and the implementation of appropriate control measures for any identified cross contamination hazards, the requirement for any alibi labelling of M&S products, must be determined using the Decision Tree below. Each M&S finished product must be assessed against each allergen handled on site, which is not an intentional ingredient in the product and the results recorded:

  • Following completion of the risk assessment, an overall RED, AMBER OR GREEN risk rating must be established to reflect the current status of the site. This must be based on the following criteria:  Significant risks of allergen cross contamination. Alibi labelling will need to be applied. (RED)  Significant potential for allergen cross contamination, however, suitable controls and standards in place as required by this Code of Practice. (AMBER)  Minimal risk of cross contamination. Suitable controls and standards in place. (GREEN) This rating must be recorded as part of the risk assessment and agreed with the relevant M&S Technologist. Formal sign off with M&S Technologist is required.

M&S Step 5b – Factory grading onto M&S Connect

  • The agreed factory status and corresponding risk assessment must be uploaded onto M&S connect for technologists sign off The site must re-upload their risk assessment onto Connect following an annual review OR if the site allergen status changes. The M&S technologist then needs to confirm the site status. Where a risk assessment has been amended but the site status hasn’t changed, this does not need to be re-uploaded.

M&S MANAGEMENT OF FOOD ALLERGENS SECTION B: FACTORY STANDARDS February 2016 v10

M&S 2.0 Production standards and controls

M&S 2.1 Raw Materials

  • Raw materials include those foods supplied as an ingredient, compound ingredient, additive or processing aid. This also includes packaging suppliers. It is the responsibility of all Marks & Spencer direct food suppliers to establish which of their raw material suppliers have allergens present on site at any time, and whether ingredients they supply pose a risk to Marks & Spencer products. Where such a risk exists, our direct suppliers must carry out an audit of the site to assess allergen cross contamination risks. Any improvements identified as necessary to eliminate or reduce cross contamination risks, must result in an agreed plan of action with the raw material supplier together with timescales for completion. Agreement on whether the use of this raw material is permitted must be agreed with your M&S technologist Note: where a significant cross contamination risk exists, then this should prompt a discussion with the relevant Marks and Spencer Technologist to establish the next stage of action and whether the risk can be lowered to an acceptable level. Audits must be carried out by suitably qualified and experienced staff and future audit frequencies established based on audit findings and risk assessment. Marks & Spencer direct food suppliers must ensure that their raw material suppliers inform them immediately if allergens are to be introduced into their premises or if there are any other changes in circumstances which could affect their compliance with this Code of Practice and Guidelines. Any risk assessments which have taken place must then be repeated. Raw material and packaging supplier specifications must include declarations as to the presence of any allergenic products or ingredients on their sites. The relevant Marks & Spencer Technologist must be informed immediately if there are any changes to the circumstances of raw material suppliers which could affect the status of Marks & Spencer products which do not carry advisory labelling.

M&S 3.0 Handling of raw materials

  • 3.1 Delivery and receipt Packaging must be in good condition during transport and distribution. Intake checks must specifically refer to the presence of allergens, and must verify that packaging is not damaged and there are no signs of any spillage. Goods on pallets must not be over hanging as this makes them more susceptible to damage. Checks should also be carried out to confirm that all ingredients, including allergens, are fully and clearly labelled. Raw materials should be clearly labelled with the allergens they contain unless this is clear and obvious from the normal pack outer labelling. Deliveries must be rejected if the above criteria are not met.

  • 3.2 Raw material storage Raw materials containing allergens should be stored in dedicated and clearly marked areas and must be fully sealed in their packaging at all times. Where practical e.g. when a small number of allergenic raw materials are being handled on site, these must be stored separately in clearly marked areas. Alternatively, where limited space makes it impractical or a larger number of allergens are being handled, these materials must be kept fully sealed within their packaging and not in direct contact with any other food or packaging materials and stored below other materials if there is a risk of contamination from spillage e.g. dry powders. Staff must be trained to look out for any damage to packaging or spillage. In the event of any spillage, there must be a suitable and effective procedure for removing debris to eliminate any cross contamination risk

  • 3.3 Handling of Raw Materials The extent of raw material handling will vary depending on products manufactured. Typically, it will include:  Decanting from outer packaging into secondary containers  Quality checks, sorting  Sieving or filtration  Weighing up  Transfer into production (including across a barrier where High Care food products are manufactured). Suitable procedures and practices must be put into place at every stage of raw material handling, to prevent cross contamination of allergenic materials to other raw materials, work in progress, finished products and packaging.

  • 3.4 Decanting from outer packaging into secondary containers Where an allergenic raw material is being handled, a separate and dedicated room should be used for decanting the material from its outer packaging. Where, due to limited space this is not practical, these materials should be handled/used last in the day within the decanting area, followed by thorough cleaning of the area and all utensils. In the case of continuous 24 hours/day production or where allergenic materials are used on an ongoing basis throughout the production cycle, immediate and thorough cleaning of the area and all relevant equipment and utensils should take place after each time the allergenic materials are used. Separate utensils must be used, which are dedicated for use with the allergenic material. Other raw materials or ‘work in progress’ (allergenic or non-allergenic) should not be kept in close proximity and should be adequately protected against potential cross- contamination. Staff should always wash their hands immediately after handling any allergenic materials before moving onto another task. Where an allergenic raw material is passed through a transfer ‘sanitizing tunnel’ eg into a High Care area, adequate checks should be carried out to confirm the integrity of the packaging and labelling. The containers holding decanted allergenic raw materials should be dedicated to each material being handled, clearly labelled with the contents and effectively lidded or sealed.

  • 3.5 Sieving and filtration Separate sieves and filters should be used for allergenic material. Where allergenic materials are being sieved a separate area should be provided, particularly where dust is generated (e.g. soya flour). Where smaller quantities of allergens are handled, the same sieves or filters can be used, however, suitable and effective procedures must be in place to ensure that they are thoroughly cleaned after use with the allergen. Appropriate assessments must have been carried out to prove that cleaning procedures effectively remove the allergenic material(s). Allergens must be sieved / filtered into containers or bags which are immediately lidded or sealed and clearly labelled as containing allergenic material. Lidding and sealing must effectively prevent any accidental spillage.

  • 3.6 Weighing up Where an allergenic raw material is being handled, a separate and dedicated area should be used for weighing up. Where, due to space limitations or where a number of different allergens are being handled, this is not practical, these materials should be handled/used last in the day within the decanting area, followed by thorough cleaning of the area and all utensils. In the case of continuous 24 hours/day production, or where allergenic materials are used on an ongoing basis throughout the production cycle, immediate and thorough cleaning of the area and all relevant equipment and utensils should take place after each time the allergenic materials are used. Separate utensils must be used, which are dedicated for use with the allergenic material. Allergens must be transferred into containers or bags which are immediately lidded or sealed and clearly labelled as containing allergenic material.

  • 3.7 Quality Checks / Sorting Where sampling of allergenic ingredients is required, steps to prevent the accidental contamination of other ingredients must be in place. Personnel taking samples should immediately wash their hands after taking samples. Samples should be sealed during transport around the factory. Where sorting and inspection is necessary, the following precautions should be taken: Carry out the sorting / inspection in a designated area, using dedicated equipment. Where it is not practical to provide dedicated equipment, sorting / inspection must be followed by thorough cleaning of the area and relevant equipment. Staff carrying out inspection and sorting must wash their hands after sorting has taken place.

  • 3.8 Transfer into production Methods for transferring raw materials into production areas will vary depending on products manufactured. Typically, this will include:  Bulk transfer from tanks / silos through pipe work  Transfer of decanted material in containers by hand, on wheels and racks, or by mechanical means (e.g. pump truck)  In weighed / batched up lots (in small bags)  Directly into production in secondary packaging as supplied by the ingredient manufacturer.

  • 3.9 Bulk transfer from tanks / silos through pipe work Tanks, silos, pipework should be dedicated to the raw material being used unless it can be shown that effective cleaning between different products is achievable. Appropriate assessments must have been carried out to prove that cleaning procedures effectively remove the allergenic material. This would need to include specific testing for residues of the target allergen after cleaning has been completed. Transfer of decanted material in tubs and containers by hand, on wheels or by mechanical means (e.g. pallet truck) Dedicated and clearly labelled containers should be used for allergenic materials, however, where this is not practical; labelling can be used on its own as an alternative, providing the containers are effectively washed after every use. Labels must be clear and adhere well so as not to present a foreign body risk.
    Containers must be lidded or effectively covered to prevent any spillage. If containers of ingredients are retained in production areas for future use, they must be lidded or covered at all times and clearly labelled. These materials should be stored in clearly designated areas and separated from other ingredients, however, where this is not practical due to space limitations, as a minimum standard the materials must be effectively contained/sealed so they are adequately protected from contamination.

  • 3.10 In weighed / batched up lots (in small bags) Bagged weighed up batches must be fully sealed and clearly labelled. Bags must be protected from damage during transport. For example, it may be necessary to place the sealed bags into a plastic container. Empty bags must be removed immediately and disposed of after use. Directly into production in secondary packaging as supplied by the ingredient manufacturer e.g. tubs of mayonnaise The ingredient must be clearly labelled as containing allergenic material. Packaging must be protected from damage during transport. For example, it may be necessary to place the packaged ingredient into plastic containers. Empty packaging must be removed immediately and disposed of after use.

M&S 4.0 Product manufacturing

  • 4.1 Use of dedicated equipment Where allergenic ingredients are being handled, dedicated production areas, lines and associated equipment should be used in order to achieve effective segregation. Where available, surface testing for the target allergen must be used to establish risk of contamination as part of the decision making process. If providing dedicated production areas/lines, is not practical and/or necessary e.g. allergens used in majority of products manufactures on site, the following methods for segregating allergenic and non allergenic material should be implemented, dependant on individual site circumstances:
     At all stages of production, products which include allergenic material should be scheduled for preparation and manufacture last in the production day, followed by effective cleaning of all relevant equipment and associated areas.  In the case of continuous 24 hours/day production, or where allergenic materials are used on an ongoing basis throughout the production cycle, immediate and thorough cleaning of the area and all relevant equipment and utensils should take place after each time the allergenic materials are used.  Only minimal quantities of the allergenic ingredient should be brought to the production line, ingredient packaging must be subject to ongoing visual checking to ensure it is intact.  Empty ingredient containers must immediately be removed for cleaning.  Staff must wash their hands as soon as production is completed, or if they leave the designated ‘allergen handling area’.  Staff moving between production lines/areas must ensure they do not pose a cross contamination risk.  Work in progress allergenic ingredients should be removed and stored in sealed / lidded containers and clearly labelled, immediately after the production run has finished.  Waste must be bagged, removed and disposed of immediately.  Effective cleaning of the production line must be carried out after the production run to remove any cross contamination risk.  Where substances such as machinery lubricants and baked food product releasing agents are used, they should be checked to ensure that they do not contain any allergenic material eg soya lecithin

M&S 5.0 Cleaning and cleaning assessment

  • 5.1 Cleaning Manufacturing Areas and Equipment Thorough and effective cleaning to control allergen cross contamination risks should take place after the manufacture of allergenic materials has been completed. Cleaning methods must minimise the risk of traces of allergenic material being spread to other areas or equipment e.g. use of manual methods instead of high pressure water hoses. Cleaning equipment used in areas where allergenic materials have been used for production must be thoroughly cleaned immediately after cleaning is finished. Methods for transporting cleaning equipment to minimise the risk of spreading contamination should be used. Where practical, dedicated and colour coded cleaning equipment should be used.

  • 5.2 Tray washing machines and areas Tray washing standards and automatic equipment must remove all traces of allergenic material from the surface being washed. Appropriate assessments must have been carried out to prove that cleaning procedures effectively remove the allergenic material(s).

  • 5.3 Cleaning assessment The finished cleaning standard should be ‘no visible debris remaining’, for cleaning in connection with allergenic ingredients. This applies to product changeover and deep cleaning. The effectiveness of removing traces of allergenic ingredient must be assessed through specific testing for the target allergen where a test method is available (see allergen testing guide page 18) Where a test method is not available, traditional microbiological and rapid test methods (eg ATP measurement) must be used to verify cleaning effectiveness. Tests should be carried at an appropriate frequency based on:  Food and non food contact surfaces  Track record of results. In addition, equipment must be risk assessed to identify any areas where removing allergen traces might be difficult, and where such areas are identified, positive release systems should be used based on inspection and surface testing for allergen traces. Evidence of risk assessment and the results of inspection and testing should be retained eg. mixers, filters, ovens, fryers, spiral chillers, vacuum cooling.

M&S 6.0 Removal of waste

  • Waste generated as a result of preparing and manufacturing allergenic ingredients must be controlled, to minimise risks of contamination to other products. Effective clean as you go must be in place to minimise the build up of waste. Waste must be stored securely to minimise the risk of spillage. Routes for the removal of waste should avoid areas where other ingredients or products are being handled.

M&S 7.0 Packing and dispatch

  • Precautions must be taken to ensure that the correct packaging is used for products containing allergenic ingredients, particularly where packaging formats for a range of products look similar. Label verification systems should be in place to minimise/eliminate wrong product in wrong packaging. This is a mandatory requirement when packing children’s products (see also Marks and Spencer Nutritional Guidelines for Children’s food) Documented checks that the correct packaging is being used must be in place. These checks must only be carried out by supervisory staff who have received full training in allergen controls. Clear and effective procedures for issuing packaging must be in place. Records of packaging issued, which include the time of issue and the line the packaging has been issued to, must also be in place. Physical segregation of products containing allergenic ingredients in despatch storage areas is not required; however, effective ‘clean as you go’ must be used to deal with any spillages.

M&S 8.0 Accidental spillage

  • Clear and effective procedures must be in place to deal with accidental spillage of allergenic ingredients, particularly in areas where non allergenic products and ingredients are exposed. As soon as a spillage has occurred, the risk of contamination to other materials must be established, and quarantine/destruction systems implemented as necessary. Any spillage must be cleaned up immediately, and the cleaning equipment removed for cleaning (see section 4.1.1 for requirements relating to cleaning activities).

M&S 9.0 Emergency evacuation

  • Emergency evacuation (e.g. in the case of a fire alarm being activated) may result in contamination with allergenic material. Therefore, the following apply: There must be clear procedures in place when returning to production area to minimise allergen cross contamination. Cleaning as outlined in this document must be carried out to decontaminate affected areas.

M&S 10.0 Trainingoffactorypersonnel

  • Compliance with the detailed requirements of this Code of Practice relies upon the implementation of effective GMP and a clear understanding of the consequences of accidental contamination of products with allergenic material. Comprehensive staff training must be carried out to support this. All staff on site should be trained. This training must include:  Explanation of anaphylaxis and common food allergens.  The general precautions that are in place on site to prevent contamination with allergenic material.  Specific precautions in place that relate to individual job roles. Training must be carried out for new employees (including temporary staff) before they start work for the first time. Training for all other staff must be completed within 6 months of the issue of this Code of Practice. The training programme should be rolled out based on risk assessment. Supervisory staff should be given specific responsibility for ensuring that staff teams comply with procedures they have been trained against. Refresher training should be repeated at least every 2 years, and if staff demonstrate lack of understanding at any time. All training must be fully documented.

M&S 11.0 Visitorsandcontractors

  • 11.1 Briefing Contractors and visitors must be made aware of the issue of anaphylaxis and that allergenic materials handled on the site are subject to controls. Records confirming that briefing has been completed must be maintained for all visitors and contractors.

  • 11.2 Supervision Visitors and contractors must be supervised as necessary to ensure they fully comply with company allergen policy and procedures. Where contractors are unsupervised, they must be fully briefed on the allergen control procedures.

M&S 12.0 New product development and production planning

  • 12.1 Development As far as practical an allergenic ingredient should only be used if there is an absolute need. Alternative ingredients (e.g. corn flour instead of wheat flour) should be considered. Where practical an allergenic ingredient should be added to the recipe as late as possible to minimise cross contamination The development team must be fully trained in all aspects of allergen management. Communication channels between NPD and the Technical Team must be clearly established. NPD procedures must include a critical path which assesses compliance with allergen policy and procedures, and confirms that any necessary changes to procedures are fully implemented before production of new recipes or factory trials commence. Checks for correct allergen labelling must be included within new packaging sign off procedures.

  • 12.2 Production Planning The Planning / Production scheduling team must be fully trained in all aspects of allergen management. Communication channels between the Planning and the Technical Teams must be clearly established. Re-scheduling or planning procedures must include communication to technical teams, to allow them to assesses compliance with allergen policy and procedures, and establish any necessary changes to procedures to deal with scheduling changes.

M&S 13.0 Policyandprocedures

  • 13.1 Allergen Policy There must be a documented Allergen Policy in place which includes detailed segregation procedures.

  • 13.2 Application of HACCP Assessment of allergen risks must be included within the HACCP study. The requirements of the Marks and Spencer Code of Practice and Guidelines on HACCP apply. As examples, the following aspects of allergen management should be included within the HACCP system:  Verification of cleaning standards of key pieces of equipment by surface testing and visual inspection.  Checks to confirm that the correct packaging has been used on finished product.  Checks on the condition of packaging when allergenic ingredients are transferred into production areas, either directly or via a sanitiser tunnel. Pre requisite CCP’s must be challenged with allergens in mind.

  • 13.3 Record Keeping Where not already in place as part of GMP, records must be kept to demonstrate that production relating to the handling of allergenic material was effectively controlled. Typically, as a minimum, records should be maintained for the following activities:  Raw material intake checks  Confirmation of sieves or filters used, and that cleaning was completed after use with allergenic material  Records of equipment cleaning, where cleaning is carried out to achieve allergen segregation, including finished cleaning assessment  Where the same production line, equipment or area is used for allergenic and non-allergenic products, records of precautions taken eg. Use of signage, cleaning. (as per section 3.4)  Checks that the correct finished product packaging was used.  Records of product quarantine, cleaning and checks on cleaning standards after accidental spillage of allergenic material.

  • 13.4 Verification and Review A self audit programme must be in place which challenges all aspects of allergen management. Audits must be carried out by personnel who are sufficiently experienced and trained. The audit frequency should be not less than quarterly.
    The senior management team must review the findings of audits, and ensure that any necessary corrective action is implemented. A programme of surface testing must be in place to verify the effectiveness of segregation procedures. A proportion of testing must be specific for the target allergen where test methods are available. The programme of testing must be based on risk assessment, with a focus for example on likely points of cross contamination or areas which are difficult to clean. Regular reviews of the Allergen Policies and procedures must be carried out. This must include:  Customer complaints relating to allergic reactions / sickness  Results of self audits  Results of customer audits  Reported factory floor issues  Results of product and surface testing  Available new scientific information

  • 14.0 Customer complaints There must be an effective system in place to investigate any complaints of allergic reaction or sickness which could be related to use of allergenic products on site. When following up each individual complaints, take the approach that compliance must be proved rather than assumed. All Serious investigations must be saved onto Connect.

BRC 5.3 Management of Allergens v7

  • 5.3.1 The site shall carry out an assessment of raw materials to establish the presence and likelihood of contamination by allergens (refer to glossary). This shall include review of raw material specifications and, where required, obtain additional information from suppliers, for example through questionnaires to understand the allergen status of the raw material, its ingredients and the factory in which it is produced.

  • 5.3.2 The company shall identify and list allergen-containing materials handled on site. This shall include raw materials, processing aids, intermediate and nished products, and any new product development ingredients or products.

  • 5.3.3 A documented risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross-contamination is avoided. This shall include: • consideration of the physical state of the allergenic material (i.e. powder, liquid, particulate) • identification of potential points of cross-contamination through the process flow • assessment of the risk of allergen cross-contamination at each process step • identification of suitable controls to reduce or eliminate the risk of cross-contamination.

  • 5.3.4 Documented procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination into products not containing the allergen. This shall include as appropriate: • physical or time segregation while allergen-containing materials are being stored, processed or packed • the use of separate or additional protective overclothing when handling allergenic materials • use of identified, dedicated equipment and utensils for processing scheduling of production to reduce changes between products containing an allergen and • products not containing the allergen
    • systems to restrict the movement of airborne dust containing allergenic material • waste handling and spillage controls restrictions on food brought onto site by staff, visitors, contractors and for catering purposes

  • 5.3.5 Where rework is used, or reworking operations are carried out, procedures shall be implemented to ensure rework containing allergens is not used in products that do not already contain the allergen.

  • 5.3.6 Where the nature of the production process is such that cross-contamination from an allergen cannot be prevented, a warning should be included on the label. National guidelines or codes of practice shall be used when making such a warning statement.

  • 5.3.7 Where a claim is made regarding the suitability of a food for allergy or food sensitivity sufferers, the site shall ensure that the production process is fully validated to meet the stated claim and the effectiveness of the process is routinely verified. This shall be documented.

  • 5.3.8 Equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination by allergens. The cleaning methods shall be validated to ensure they are effective and the effectiveness of the procedure routinely verified. Cleaning equipment used to clean allergenic materials shall either be identifiable and specific for allergen use, single use, or effectively cleaned after use.

Morrisons 5.3 Management of Allergens v4

  • 5.3.0.1 The control of allergens shall be conducted in accordance with „TP01 - Policy for the Control and Labelling of Allergens in Morrisons Food & Drink‟. Where applicable, the requirements of „TP05 – Technical Policy for Morrisons Free From Products‟ shall apply.

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