Allergen Control Policy/Plan of Action (POA)

We MUST  control the risk of allergen cross-contact  & to prevent mislabeling of ALL product(s). 

We are a 100% vegan (dairy & meat free) facility but so utilize tree nuts, peanuts, wheat, soybeans & sesame products.

8 foods / food groups as the major allergens;

  1. Milk

  2. Eggs

  3. Fish

  4. Crustacean shellfish (e.g. shrimp, crab, lobster)

  5. Tree nuts (e.g. almonds, walnuts, pecans, etc.)

  6. Peanuts

  7.  Wheat

  8.  Soybeans

  9. Sesame

Receiving

  • Follow all SOP’s

  • Reject ALL containers that do not contain legible ingredient labels

  • Reject ALL damaged containers

Storage

  • Follow all SOP’s

  • Allergens cannot be stored above or on top of non-allergens.Allergen-containing raw materials are segregated and stored on lower racks so, if there is a spill, the ingredients will spill onto the floor and not on top of other ingredients.

  • Exercise care to prevent allergens from becoming airborne.

  • Any & all  products containing allergens will be stored with sealable covers or  barriers. 

  • Products must be clearly labeled to indicate the specific allergen(s)

  • Spills are cleaned as soon as possible to minimize cross contact.

  • Containers are kept clean and sealed. Bags are kept clean and sealed with tape.

  • When possible, storage areas are designated for allergenic and non-allergenic ingredients.

  • All boxes, bags and buckets/pails are completely sealed at all mes.

  • Labels on all containers are readable.

  • Ingredients containing allergens are separated from non-allergen ingredients

During Manufacturing

Follow all SOP’s

  • Always handle products that contain allergens last. Always handle products that do not contain allergens before those that do. Production is scheduled in a manner to minimize cross contact. Non- allergenic products are processed 1st whenever possible.

  • If utilizing  multiple allergens, between each one: ● wash hands with soap and water – or if disposable gloves are worn, replace them. ● clean equipment that is used to process different food allergens; allow to air dry. ● document that cleaning steps have occurred.

  • If equipment is used – such as scoops, aprons, containers or scales – designate separate ones for each allergen, or clean equipment between handling of different allergens. 

Sanitation 

  • Gloves are discarded after handling allergens. 

  • Utensils are cleaned and sanitized after handling allergens.

  •  Boxes, bags and pails are closed or sealed with tape after use. 

  • A full clean-up is scheduled at the end of each production day

  • Use a chlorinated alkaline clea ner w/appropriate cleaning tools to completely remove the protein fraction that contains the allergens  

Packaging and labeling

  • Follow all SOP’s

  • Inspections of labeling on packages, either just prior to distribution or during production

  • FALCPA requires that foods or ingredients that contain a "major food allergen" be specifically labeled with the name of the allergen source.

  • FDA requires all products containing FD&C Yellow No. 5 to identify it on their labels so consumers who are sensitive to the dye can avoid it. 

  • Always refer to the FDA’s “Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food” rule (CGMP & PC rule, 21 CFR part 117) It stated the requirements applicable to establishments that manufacture, process, pack, or hold human food.

  • ALL labels that DO NOT contain allergens should list that the product was produced in a facility that is NOT allergen free. 

  • List precautions→ If the Brownie contains walnuts, at the top of the label AND in the ingredients, list the allergen & place a caution statement at the top with the specific allergens

Staff Training & Education

Provide general training on allergen awareness and control for all employees at all levels of the company. Potential consequences should the plan not be followed.

 Corrective Action:

1. Determine the root cause of the cross-contact/ contamination 

2. If the cause is due to employee error, retrain the employee and document training.

3. If the cause is due to labeling error, re-evaluate labeling scheme and document any revisions. 

4. Evaluate whether any lots may have been impacted by cross-contact. 

5. Activate recall procedures if cross-contact is found to have occurred.

A log is kept in the Royally Baked Playbook. This plan MUST be revisited & updated ANNUALLY IN JANUARY

**Updated 1/22/24