Facility management is responsible for the development and implementation of a training program for the prevention of both cross-contamination of pathogens and cross-contact of allergens, says Knutson. “Training starts with the on-boarding of new employees, seasonal workers or temporary hires before the worker goes to their first position on the production floor. From the first day of employment, the worker must be trained on the hazard of undeclared allergens, the facility’s color code for labeling of allergenic ingredients, use of personal protective equipment (PPE), and encouraged to report concerns or hazards associated with allergens. Facility management creates the food safety culture inclusive of allergen management and conducts refresher training as needed.”

All new hires and plant personnel should have training on what allergens are and how they affect the food industry, says Bret Zaher, manager, operations, Americas, AIB International, Manhattan, KS. “A list of known allergens at the plant should be provided to everyone and displayed at numerous locations around the facility. Allergen training should also include gluten training and training on specific allergens for any country the plant may export to,” he adds.

Establishing safe storage and handling practices are a must to prevent possible cross-contamination, Zaher notes. “It is a best practice that receiving personnel have a list of materials that contain allergens and these items are clearly labeled with allergen identification stickers (color-coded is best practice). There should be dedicated storage locations for the allergens, preferably on the bottom rack to prevent spillage. Like allergens should be stored over like allergens,” he explains.

It is also suggested that divider walls be provided in the storage slots to further assist in containing the allergens, Zaher adds. “Dedicated and/or color-coded containers and utensils should be used for handling these items. Dedicated and/or color-coded cleaning utensil should also be provided. Many sites have sectioned off allergen product lines from the other lines and have dedicated uniforms and color-coded hairnets for workers on those lines. Positive air pressure and dust collection systems in the pre-scale and mix areas are a must for dry ingredients that are allergenic.”

Employee traffic patterns should also be considered to prevent cross-contamination, too, Zaher says. “Risk assessments should also be conducted for any possible lunch room allergens being brought in by employees and ensuring that these are restricted to designated areas.  Many sites do not allow certain allergens, like peanuts in a peanut-free facility, to be brought into the lunch room.”

Staying on track

Zaher gives some examples of scenarios where software could be useful in allergen control, including altering staff when a line requires sanitation, alerts to prevent cross-contamination, and protocol for testing for allergies.

“Manufacturers can help keep personnel on track with allergen control through computer programs. Many plants are also sending out automatic email and text messages to their supervisory staff when allergen change-overs are due,” says Zaher. “ELISA-specific protein testing is the best way to validate that a company’s allergen cleaning is effective. A comprehensive food contact testing program should take place as well.”

Knutson recommends performing an allergen clean validation as part of SSOPs. An allergen clean is used to remove allergens on food contact surfaces after the production of one product and before starting production of a second product without the allergens.

“Despite not being required by FDA’s Preventive Controls for Human Food rule, 21 CFR 117, validation of an allergen clean is highly recommended. Validation of an allergen clean is a research project that is done once using allergen swabs on a multitude of difficult to clean food contact surfaces. Following the validation study, cleaning can be verified with lower-cost protein swabs at a frequency determined by the facility,” explains Knutson.

The validation study, allergen clean procedures, and swab procedures must be written along with the use of associated records for documentation of the allergen clean and verification, Knutson says. “Electronic programs to alert employees for the requirement of an allergen clean can be developed, and electronic recordkeeping can demonstrate that an allergen clean was completed and verified. Employees, equipment and utensils on a line with a unique allergen must be dedicated during use. Employees on a line with a unique allergen can be provided with color-coded hairnets or other PPE to show supervisors that they are at the correct work station. If the employee is moved off one line and to another line, the employee must leave the production area, remove all PPE and don new PPE to prevent cross-contact.”

Knutson says she spoke with the managers of a company that has a nut line and a nut-free line. In that example, employees have electronic key cards to access the line where they are to work. The employee will not have access to a line, if the employee is not scheduled to work on the line. “Traffic patterns for all personnel, wheeled equipment such as forklifts and garbage cans, and maintenance personnel and their tools must be controlled to prevent cross-contact,” she notes. “Tools and utensils brought to a line must be cleaned and sanitized before use. Allergen training for specific tasks should be verified by supervisors and documented in personnel files following the documentation of onboarding training.”