Transcript Training for Plant HACCP Authorities.

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Allergen Control Strategies
- A “How To” Guide
Hormel Foods Corporation
Brent Brehmer
Corporate Manager of Regulatory
Compliance & HACCP
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F/Y 2011 – Consumer Response handled
> 140,000 contacts – Top questions:
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Where to purchase products
Shelf-Life questions
Coupon requests
Allergen & Gluten questions
Actual Customer
Comments/Questions
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“Is Chi Chi’s Salsa gluten free?”
“Is there dairy is potassium lactate?”
“I just wanted to thank you for going the extra mile for people w/
Celiac Disease. I noticed you even put “gluten-free” on some of
your labels. My 5 yr old has the disease & she loves your
pepperoni. I can’t tell you how hard it is to stick to her diet & I am
so thankful for companies who have regular food that is gluten-free
so our whole family can eat the same foods. I can tell you that as
long as you’re taking the precautions to keep them gluten-free, I
will be a devoted Hormel customer…”
Allergen Program – What Does One
Look Like?
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Hormel’s
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110+ Food Safety Assessments
30 GFSI Audits Annually
Dozens of Customer Audits
Allergens & HACCP
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Allergens are a “Chemical” Hazard
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Control Point or CCP?
Prerequisite Program
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Hazard = presence of an Unlabeled Allergen
Hazard Not Likely to Occur
Ingredient Usage Page - Added “Allergen”
section.
Added
“Allergen”
Category
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Possible CCPs
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Product Changeover
Labeling
Control of Rework
Starts at “Product Formulation”
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R&D
Product Development Strategies
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Determine allergenicity of ingredients;
Avoid allergenic ingredients which have no
functional effect on the finished product
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Find substitutions for allergenic ingredients!
Identify Allergens on Formulas sent to plant.
Hormel’s Allergen Program
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“Big 10”
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List on file:
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Big 8 + Sesame Seeds + Molluscan Shellfish
At Corporate
In Plant
New Ingredients
HACCP Plan.
Incoming Ingredients – Labeling
Requirements of Allergens
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“Allergen” Sticker on each Pallet
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Supplier Applies
If not on,
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5” x 8”
Brightly Colored
Apply at Receiving &
Notify Supplier
Easily readable on walk-throughs.
Storage of Ingredients
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Ideal - Dedicated Room or at Least Rows
Realistic – No Allergens stored above nonallergenic product.
Open to contamination or able to
cross-contact other products.
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“Cross Contact” NOT
“Cross Contamination”
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Milk Item
Improper Storage
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Storage of Ingredients - Bulk
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Containers Labeled
Dedicated (Color-coded) Scoops
Procedures - Employees in Spice Rooms working
w/ Allergens must:
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Wear Disposable outerwear (sleeves, aprons & gloves);
Change outerwear & wipe down helmet at:
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Each break
When changing to other non-allergen product.
Product Scheduling
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Huge
More important than “color” issues
Order must be:
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Non-Allergen first
Allergen #1
Allergen #1 & Allergen #2
Etc.
Allergen Cleanup
Changeovers – Validation of Cleanups
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3 Separate Runs on our Production Lines
Choose Product Based On:
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Run Allergenic Product & Pull Control Sample
Conduct the planned “Allergen Cleanup”
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Record Procedures Used (Full 4-Step Cleanup, Water Rinse,
Sugar Rinse, etc.)
Run Non-Allergenic Product & Pull Samples:
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Highest Percentage in Product
Toughest to Clean (i.e. Burn-On)
First Unit, after 5 minutes, after 10 minutes
Changeovers – Validation of Cleanups
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Test Control Product & Changeover Product
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University of Nebraska (Lincoln) – FARRP or
On-Site using approved test kits (i.e. Neogen® - pending Corp.
approval)
Must choose Level
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HOLD ALL PRODUCT PENDING RESULTS!!!!!
Disposition
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i.e. 10 ppm, 5 ppm, 2.5 ppm
“Negative” – Release Product
“Positive” – Contact Corp. QC for disposition
Record Results on “Allergen Validation Testing Record”
Neogen.com
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Rework Requirements
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Label
Store Properly
Exact Into Exact
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NOT Like Into Like
Record Code Dates
Implement Rework Cycle Breaks.
Procedures for “Suspect” Product
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Place all suspect product on HOLD;
Call Brent
Label Verification Program
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Incoming Labels
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Pull 1 from each incoming lot - Place on Hold until:
Compare the Big 9 (Hormel Term)
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Ingredient Listing
Est. #
Nutrition Facts Panel
Net Wgt
Address Line
Safe Handling Instructions (Raw items)
Product of Identity
Manufacturer ID (37600 on Bar Code Label)
SI # + Version
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S0044208-24 (15 oz. CWB – 24th version)
Incoming Multiple-Component
Ingredients
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Place on Hold
Compare Ingredient Listing to Approved File.
Formulation Changes
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Line Trial System –
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If Approved
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New Product
Reformulation
Unique Number Assigned to Each
Hold & Release Program
System in place to convert
Formulation Verification (Batching)
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Record Item / SI numbers
Record Lot Numbers
In-Process Labels
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Verify amounts used
Restricted Ingredients
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Must have Ingredients listed
Stored under Lock & Key
Packaging Line Procedures
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Save 1 label per Roll (or case);
Verify Big 9;
Corrugate (save 1 box / pallet);
3 Individuals (min. of 2 mgt.) Verify
Ingredient / Product Spills
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Cleaned in a manner as to prevent any
cross-contact.
Packaging “Leakers”
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Dispose of Properly
Properly clean line.
Allergen Training
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Annual Training of all employees
(30 minutes)
Record
Obsolete Labels
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Isolated
Destroyed
Hold Requirements
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Normal Hold for “Quality” Issues
Category 1 Hold – Food Safety Issues
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Pathogen Testing
Allergen Testing
“Daily Inventory”
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Electronic (minimum)
Physical (when possible)
Internal Audits Conducted by
Corporate – “Quality Cup”
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If score > 90 in each
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HACCP
Sanitation
Quality
No Product Recalls or
Market Withdrawals
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AND > 80 in each
“Quality” Category:
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Foreign Material
Food Defense
Wgt Control
Label Verification
Thermal Processing
Minimizing the Window
Ingredient Receiving
Additional Site Specific Actions
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High-Speed Packaging Lines
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Red & Yellow Hormel® Chili
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500+ cans / min.
Bar-code reading systems
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CNB – Soy & Wheat
CWB – Soy only
(See next slides)
SI #
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Questions?
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