By Ryan Gembala, ODMP Attorneys and Counselors
One way or another, most of us are subject to the statutory and regulatory provisions of FSMA. While some of these provisions are merely codifications of good manufacturing practices (GMPs), others are new and different requirements. Here, I am going to discuss allergen control plans, why you (may) need one, and some of the things that should be included within one.
FSMA regulations require most in the food and beverage industry to have a written food safety plan. Among other important elements, the food safety plan must contain a written hazard analysis and written preventative controls. Why is this important to an allergen control plan? Because federal regulations identify cross-contact of food allergens as a chemical hazard. Practically speaking, this means if you operate a facility that has both allergen-containing and allergen-free products, or allergen-containing products with different allergens, you have a cross-contact hazard. This hazard should be identified in your hazard analysis and a preventative control should be put in place. That preventative control will be your allergen control plan.
All preventative controls, including allergen control plans, must be in writing and must provide assurances that the applicable hazard (in our case allergen cross-contact) will be significantly minimized or prevented. When writing food allergen controls, you should consider the three Ps — procedures, practices, and processes — to control food allergens.