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Allergen management review

Segregation, scheduling, changeover cleaning and validation assessed as they run, with a control plan for every gap between the procedure and the practice.

What is allergen management?

An allergen management review assesses the controls a site relies on to prevent allergen cross contact, from goods receipt through storage, production scheduling, changeover cleaning and validation. It covers what happens physically on the site, as distinct from what the label declares. Cleaning validation is normally the element that decides whether everything else holds.

Almost every control on the site rests on one piece of evidence. If changeover cleaning has not been validated, then shared equipment cannot be justified, sequencing decisions cannot be evidenced, and a free from position on any label has nothing behind it. Most sites have verification records and no validation.

Summary

The controls behind the declaration, assessed as they run. Validation position stated plainly, and the precautionary labelling question answered on evidence.

Allergen review at a glance

Covers
Receipt, storage, decanting, scheduling, cleaning, rework
Standards
BRCGS, IFS, FSSC 22000, ISO 22000, SQF, customer codes
Central to it
Cleaning validation evidence
Delivery
On site, since practice is the subject
Output
Control plan and validation position
Pairs with
Allergen declaration review
Coverage
Worldwide
Languages
Any language, including English, Spanish, French, German, Italian and Portuguese

Allergen control points

Eight points where cross contact is created or prevented, each assessed against what happens on the floor.

Control pointWhat good looks likeCommon failure
Goods receiptAllergen containing materials identified on arrival, checked against specification, and segregated before they enter storage.Materials accepted on a delivery note with nobody checking the allergen status.
StoragePhysical segregation, or separation by height so allergen material cannot fall into non allergen material.Allergen containing bags stored above open non allergen material.
Decanting and weighingDedicated equipment, controlled sequence, and cleaning between materials.Shared scoops and scales moving between allergen and non allergen ingredients.
Production schedulingSequenced so non allergen product runs before allergen product, with full clean between where sequencing is impossible.Schedules built for efficiency with allergen sequence considered afterwards.
Changeover cleaningA validated procedure demonstrated to remove allergen residue to the required level.A cleaning procedure assumed effective with no validation evidence behind it.
ReworkLike into like only, with lot identity and allergen status carried into the receiving batch.Rework reintroduced without its allergen profile following it.
Equipment and utensilsColour coding or dedication, with cleanability assessed for shared equipment.Shared equipment with dead legs and hollow sections that cannot be cleaned.
People and clothingMovement rules, clothing changes and hand washing between allergen and non allergen areas.Operators crossing between areas with no change of clothing or hand wash.

What each cleaning check proves

Validation and verification need different methods. Using a verification tool to validate a procedure is one of the most common error in allergen cleaning.

MethodWhat it showsLimitation
Visual inspectionConfirms gross soil removal.Proves nothing about allergen residue at the levels that matter.
Protein swabsRapid, general indication of protein presence.Not allergen specific, and negatives can mislead where protein levels are low.
Allergen specific rapid testsLateral flow tests for the specific allergen.Good for verification, limited quantification, matrix effects need understanding.
Laboratory ELISAQuantified result for the specific allergen.The strongest evidence, and the right basis for validating a procedure.
Worst case validationTesting after the hardest changeover, at the least accessible points.The condition validation should be carried out under, and rarely is.

Where allergen control breaks down

Eight failures found across most sites handling allergens on shared lines.

What you receive

The validation position is stated plainly, including where evidence you believed you had does not support what it is being used for.

ElementWhat it covers
Allergen matrix reviewWhich allergens are handled, where, and whether the matrix is current.
Control point assessmentEvery control point from receipt to dispatch, assessed against practice.
Segregation reviewStorage, decanting, equipment and people movement, physically assessed.
Scheduling assessmentWhether sequencing is used as a control and where it is being wasted.
Cleaning validation positionWhether validation evidence exists, whether it was worst case, and what is missing.
Verification regimeRoutine checks confirming the validated procedure keeps working, with limits.
Rework controlWhether allergen status follows reintroduced material into receiving batches.
Control planActions for each gap, sequenced, with the precautionary labelling position stated.

Who an allergen management review is for

Manufacturers and processors handling allergens on shared lines or in shared facilities. It suits any site relying on changeover cleaning without validation evidence, and any business carrying precautionary labelling it cannot justify.

You handle allergens on shared lines and rely on changeover cleaning.

Cleaning has never been validated for allergen removal.

May contain appears on pack and you are unsure it is justified.

Production is scheduled for efficiency with allergen order applied afterwards.

Rework moves between products.

A customer or auditor has questioned your allergen controls.

You are introducing a new allergen to the site.

An allergen incident or near miss has occurred.

How the review is carried out

  • 1

    Matrix and scope

    The allergen matrix is reviewed for currency, and the products, lines and materials in scope are confirmed.

  • 2

    Flow assessment

    Allergen materials are followed from receipt through storage, decanting and production to dispatch.

  • 3

    Segregation review

    Storage, equipment, utensils and people movement are assessed physically, including height segregation.

  • 4

    Scheduling assessment

    Whether sequencing is used as a control is established, and where it is being wasted.

  • 5

    Validation position

    Existing cleaning validation evidence is assessed for whether it was worst case and whether it supports the claims made on it.

  • 6

    Control plan

    Gaps are sequenced into a plan, with the precautionary labelling position stated on evidence.

Not included

Carrying out the validation study itself. The review specifies what study is needed, under what conditions, and your laboratory performs it.

Label declarations, which are covered by an allergen declaration review. A correct declaration on a site with uncontrolled cross contact is still a hazard.

Physical remediation. Where equipment cannot be cleaned, the answer is dedication or replacement, and both are yours to decide.

What an allergen management review costs

Every review is quoted against its own scope. One line handling two allergens and a four line site handling nine are very different pieces of work. These factors set the price.

Number of allergens handled

Number of production lines

Changeover complexity

What this service is assessed against

These are the primary sources this work is built on. Where a market you sell into has its own requirement, that takes precedence and we assess against it.

Regulation (EU) No 1169/2011 on food information to consumers
Mandatory particulars, allergen declaration, quantitative ingredient declaration, nutrition declaration and legibility. EUR-Lex
CXC 1-1969, General Principles of Food Hygiene
The international reference for prerequisite programmes and for the seven HACCP principles. Codex Alimentarius
21 CFR Part 101, food labeling
United States labelling requirements including nutrition labeling and allergen declaration. eCFR
BRCGS, IFS Food, FSSC 22000 and SQF published requirements
The clause your certification body audits against, which differs between schemes and between issues. BRCGS

Allergen management terms

Cross contact
Unintended transfer of an allergen from one food to another during production, handling or storage.
Allergen matrix
A record of which allergens are present in which materials and products, and where each is handled on site.
Changeover cleaning
Cleaning carried out between production of different products, intended to remove allergen residue.
Cleaning validation
Evidence that a cleaning procedure removes allergen residue to a level that would not cause a reaction.
Verification
Routine checking that a validated procedure continues to operate as intended.
Production sequencing
Ordering production so non allergen product runs before allergen product, reducing changeover burden.
Reference dose
A quantity of allergen protein below which a reaction is unlikely in most allergic individuals.
Precautionary allergen labelling
An advisory statement covering possible unintended allergen presence, requiring a risk assessment behind it.

Allergen management questions

It is the set of controls a site uses to prevent allergen cross contact, covering goods receipt, storage, decanting, production scheduling, changeover cleaning, rework, equipment and people movement. It is distinct from allergen labelling, which describes what is in the product.

By demonstrating with evidence that the procedure removes allergen residue to a level that would not cause a reaction. Laboratory analysis for the specific allergen provides the strongest basis. The validation should be carried out under worst case conditions, meaning the hardest changeover and the least accessible points, and repeated when anything changes.

No. Visual inspection confirms gross soil removal and says nothing about residue at the levels that matter to an allergic consumer. It has a place as part of a verification regime, and it cannot validate a procedure.

Validation establishes that the cleaning procedure is capable of removing allergen residue, before you rely on it. Verification confirms routinely that the validated procedure is being carried out and continues to work. Most sites have some verification and no validation.

Non allergen product first, then products containing fewer allergens, then those containing more, with a full validated clean between where the sequence cannot be maintained. Sequencing is the cheapest allergen control available and it is routinely wasted by scheduling for efficiency first.

Only where changeover cleaning has been validated as effective on that equipment. Equipment with dead legs, hollow sections or porous surfaces frequently cannot be cleaned to the required level, in which case dedication is the only real control.

Like into like, meaning reintroduced material goes back only into product with the same allergen profile, with lot identity and allergen status carried into the receiving batch. Rework crossing product lines is among the most common causes of an undeclared allergen incident.

Only where a risk assessment shows unintended presence remains possible despite the controls you have. Where segregation and cleaning could control the risk and have never been made to work, precautionary labelling offers no defence and devalues the warning for the people who rely on it.

It records which allergens are present in which materials and products and where each is handled. It should be updated whenever a new product or ingredient is introduced, a supplier changes, or production moves. A matrix built once and never revisited invalidates everything built on it.

Rapid tests are useful for routine verification after changeover. Validation is better based on laboratory analysis. The right combination depends on which allergens you handle, the equipment involved and how frequently you change over.

A declaration review checks what the label says, working from the recipe. This review checks the controls on site that determine whether the label is true. Businesses frequently need both, and a correct declaration on a site with uncontrolled cross contact is still a hazard.

An allergen matrix review, a control point assessment from receipt to dispatch, a segregation review, a scheduling assessment, a cleaning validation position stating what evidence exists and what is missing, a verification regime with limits, a rework control assessment and a sequenced control plan including the precautionary labelling position.

Who carries out this work

Confi Food assigns work by subject. HACCP, labelling, certification standards, regulatory compliance, supplier assurance and monitoring are separate disciplines, and each piece goes to someone who works in that area. Every deliverable is reviewed internally by a second specialist before it reaches you.

Our technical positions are built from primary sources, meaning the legislation, the competent authority, Codex Alimentarius, the certification scheme owner or the relevant standards body. We set out how that works in our technical review and editorial policy, and what happens at each stage of an engagement in how Confi Food works.

Related services

Request an allergen management review

Tell us the allergens handled, the lines involved and how changeover works, and receive a written quote covering the scope, the deliverable and the price.