6.5.5 Allergen Control Procedures - GWSI Langhorne

Purpose

GWSI has a policy of not allowing food allergens into the storage areas unless a specific product formulation includes an allergen. GWSI has an allergen management program in place that prevents allergen cross-contamination from occurring.

Scope

This Procedure covers company food allergen management within the storage areas. The scope does not cover allergens in employee break time foods or any other stored food in break room vending machines. This policy does not cover latex allergens.

Responsibility

GWSI Management is responsible for developing the Allergen Management Procedure (AMP). The Warehouse Supervisor and Employees are responsible for the implementation of the AMP.

Allergen Management Procedure (AMP)

Identification of Food Allergens with Storage and Cooling Operations. The following are the allergens in the storage area of the operation:

• Acid Casein Armor Proteins (made from milk)
• Anhydrous Milk Fat
• Calcium Caseinate Spray Dried Armor Proteins
• Canned Tuna
• FS Beverages: Spiked Latte (contains cream)
• Herr’s Potato Chips (fried in vegetable oil containing soy)
• MCC German Micell Milk Proteins
• Protein Puffs (made with milk proteins)
• Wheat Gluten
• Whole Milk Powder
• WPH Optipep Protein (contains whey)

Allergen Management of Product Development

When new products are accepted into the storage facility, a review of the potential allergen status of the new product is performed, which includes the following;

Are any allergens contained within the materials?

Do the potential material suppliers handle raw materials? What label declaration is required to ensure allergen or possible allergen content is clearly shown?

Allergen Management of Material Suppliers

Supplier Allergen Status - Three situations arise:

1. Incoming material suppliers that supply products that contain allergens
2. Incoming material suppliers that supply products that do not contain allergens but do handle allergens in their production facilities containing allergens
3. When allergen materials are received, apart from the usual material checks, operators also check that an allergen-containing label is on the product. The presence or absence of this label is noted on the form Inspection Record.

When a product arrives that contains allergens but has not been labeled as such, then Receiving has a stock of allergen labels and will apply the labels.

If there is visible leakage of allergen-containing materials in the trailers, then unloading is prohibited due to the risk of cross-contamination between allergen-containing and non-allergen-containing materials.

Allergen Management of Material Storage

Allergen-containing materials are stored in designated and dedicated areas of the warehouse. Within the allergen-containing material storage areas, care is taken to store allergens of the same kind together wherever possible and avoid commingling between different allergens.

Care is taken to avoid storing allergen-containing materials in high-level racking where there is a risk of contaminating materials underneath when they contain a different allergen, i.e., to avoid top-down contamination. This is done by prevention, e.g., not storing allergens in the rack level (predominantly liquid allergen-containing materials) or storing allergens of the same type in one racking column.

A dedicated allergen-containing material clean-up kit, i.e., identified mops, brooms, et cetera., is on hand to clean up any spills. Allergen spills are cleaned up immediately to avoid the risk of cross-contamination.

Employee Allergen Training

Employees are trained regarding site allergen management plans/SOPs in their orientation training and as part of the ongoing training program (at least annually). The training includes both a classroom and an operational tour. The training covers at least the following topics: 

1. Explain what allergens are and why they are essential.
2. What allergens are on site
3. How allergens are labeled at different stages of production
4. Specific storage requirements for allergens
5. Specific designated and dedicated utensils and equipment for use with allergens.
6. Allergen production controls, e.g., production order, work-in-progress systems, et cetera.
7. Allergen sanitation requirements
8. How to handle allergen spills
9. Hand washing requirements after handling allergens (in storage and production areas and also in break room areas)