Stepping through allergen cleaning
Robust allergen management is a standard requirement in all food safety management systems. The South African food industry has been honing its allergen management skills since 2010, when the labelling and control of eight common food allergens became mandatory.
Food business operator responsibilities, in terms of allergen management, are well described in the regulations, food safety standards and retailer guidelines.
Because we cannot always have separate facilities or separate processing lines for each allergen or combination of allergens we process, we must implement allergen controls to prevent cross-contact. One of the key controls is to have validated and verified cleaning procedures.
Developing an allergen-cleaning procedure
Allergen cleaning aims to remove allergen-containing food soils from shared food contact surfaces. Soils that are not removed may inadvertently contaminate the products that follow.
The variety of available cleaning protocols is testament to the complexities the food industry faces in effectively eliminating diverse types of contaminants from surfaces. Overall, the nature of the food soil you need to remove, the food matrix, and the type of processing will determine what type of cleaning procedure will best suit your organisation.
It is important to follow a rational and practical approach when developing an allergen-cleaning procedure and programme. Figure 1 lays out the steps for developing an allergen-cleaning programme.
Step 1 – Risk Review.
The aim is to identify what needs to be cleaned, when it needs to be cleaned, and how often it needs to be cleaned. Review your manufacturing process and environment, and identify cross-contact points.
Step 2 – Set a cleaning goal.
Ideally, cleaning should remove all allergen residues and visual soils. This is not always practically achievable; thus, at a minimum, cleaning should reduce the risk or amount of allergen cross-contact as much as possible.
Step 3 – Build the cleaning procedure.
The aim is to identify how food contact surfaces must be cleaned to remove soil.
When building a cleaning procedure, ask yourself:
- What type of cleaning method will work best?
- Can we do wet cleaning, or must we do dry cleaning?
- What type of detergent will work best?
- Should we use hot water?
- Should cleaning be in our or out of place?
- What type of cleaning utensils/tools do we need?
Step 4 – Validate the cleaning procedure.
Next, the procedure must be validated, to prove it achieves the cleaning goal. The validation plan should define the validation study’s objective, method, target allergens, sampling plan, testing using suitable methods, and desired outcome. Validation studies may be based on worst-case scenarios. The rationale is that if you prove that a cleaning procedure can remove allergen soils in a worst-case scenario, it will be able to remove allergen soils in most other scenarios. The validation study must include visual inspections of equipment and processing lines pre- and post-cleaning. The presence of visual food soils after cleaning suggests a failure, and the probability that the study will fail is high. It is best practice to repeat a validation study three times.
Step 5 – Document the cleaning procedure.
If validation is successful, the procedure should be documented in a Standard Operating Procedure (SOP). Cleaning SOPs must be detailed and easy to understand; or example, they should describe the:
- Cleaning objective
- Cleaning method
- Materials and equipment required
- Authority and responsibilities
- Cleaning frequency
- Cleaning verification method and desired results
Other accompanying documents required may include cleaning records and sign-off checks.
Step 6 – Staff training.
Staff must be suitably trained and tutored on cleaning, and on the importance and significance of cleaning.
Step 7 – Ongoing verification.
Allergen-cleaning verification demonstrates that cleaning was done correctly and that the procedure remains effective. Verification is completed in actual scenarios, typically after allergen cleaning. It should always include a visual inspection and is best supplemented with testing, e.g. testing rinse water or swabbing identified sampling points. When doing rapid tests, positive controls must be included, at least periodically, and results must be recorded in a preformulated record.
Last but not least, it is important to continuously review and improve the cleaning procedure – at least annually, or if there are any cross-contact incidents or changes in products or processing.
Cleaning to remove food allergens is part of a food safety management system, with the purpose of preventing or minimising allergen cross-contact. However, allergen cleaning is not a one-size-fits-all approach; consequently, adopting a methodical approach to allergen cleaning is imperative to ensure that potential risks are thoroughly recognised and effectively mitigated.
Other articles and resources you may be interested in:
Infographic | Allergen Cleaning Validation and Verification
Allergen Control Resources
Hygiena® Allergen Webinar: Allergen Control Validation vs. Verification
Infographic ǀ Dry vs Wet Cleaning: Pitfalls and Solutions