Allergen Management

Aligned with BRCGS Food Safety Issue 9 – Clause 5.3: Product Control

Requirement Overview

BRCGS Clause 5.3 requires that food businesses have a fully implemented allergen management system to identify, manage, and control allergenic materials throughout the supply chain, production process, and finished product labeling.

Clause 5.3.1: “The site shall have a system for the management of allergenic materials, which includes risk assessment, handling procedures, cross-contact prevention, and accurate labeling.”

Failure to control allergens is one of the most common causes of product recalls and can pose a serious public health risk to allergic consumers.

Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3

Requirement Overview

BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.

Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”

Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.

Key Compliance Objectives

  • Identify and assess all allergenic materials on site

    Prevent unintended allergen cross-contact

    Ensure correct allergen labeling on packaging

    Train staff in allergen awareness and control measures

    Maintain allergen control records for traceability and audit

Step-by-Step Compliance Implementation

1. Conduct an Allergen Risk Assessment

  • Assessment Activities:

    • Identify allergens handled on-site (based on local regulations)

      Evaluate risk at every step—receiving, storage, production, cleaning, labeling

      Assess vulnerability to cross-contact and mislabeling

    Evidence to Maintain:

    • Allergen risk assessment document

      Updated allergen matrix and flow diagrams

      List of allergenic raw materials with supplier specs

2. Establish Allergen Handling Procedures

  • Control Measures Should Cover:

    • Segregated storage of allergenic ingredients

      Dedicated equipment or cleaning protocols for changeovers

      Scheduling strategies to minimize risk (e.g., allergen-to-non-allergen sequencing)

    Evidence to Maintain:

    • SOPs for allergen handling and cleaning

      Line clearance and changeover checklists

      Visual or color-coded identification systems

3. Verify Label Accuracy and Packaging Controls

  • Label Control Actions:

    • Check all labels against the finished product formulation

      Implement label approval and verification procedures

      Ensure correct packaging is used every time

    Evidence to Maintain:

    • Label verification records

      Final pack checks and label reconciliation logs

      Mock product labels with highlighted allergens

4. Train Staff in Allergen Awareness

  • Training Should Include:

    • The “big 8” or regionally regulated allergens

      Cross-contact risks and control points

      Emergency procedures in case of allergen exposure

    Evidence to Maintain:

    • Allergen training materials and attendance sheets

      Post-training evaluation or quizzes

      Annual refresher training schedule

5. Monitor, Audit, and Improve

  • Ongoing Controls:

    • Internal audits of allergen storage and labeling

      Periodic review of allergen risk assessments

      Investigation and corrective action for allergen-related complaints

    Evidence to Maintain:

    • Allergen audit results and non-conformance reports

      Updated SOPs based on findings

      Corrective/preventive action (CAPA) logs

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Unsegregated storage of allergens Implement physical barriers, labeling, or color-coding systems
Mislabeling or incorrect allergen info Review label approval workflows and final pack checks
Lack of allergen risk assessment Perform a documented allergen risk assessment per product line
Incomplete training records Schedule regular allergen training and maintain attendance logs

Auditor Verification Checklist

Expect auditors to review:

  • Allergen risk assessment and matrix

    Allergen-handling SOPs and changeover checklists

    Label verification records and controls

    Staff training documentation on allergen awareness

    Internal audits and evidence of continuous improvement

Implementation Roadmap

Build Your Allergen Control Program

  • Identify all allergens handled on-site

    Conduct and document a risk assessment

    Establish allergen handling SOPs

Train and Execute

  • Train all relevant staff on allergen risks and controls

    Implement segregation, scheduling, and cleaning procedures

Verify and Monitor

  • Conduct label checks, internal audits, and cleaning verifications

    Track corrective actions for any deviations

Improve Continuously

  • Update allergen controls based on complaints, recalls, or process changes

    Review allergen risk annually or with new product introductions

Why This Matters?

  • Prevents life-threatening reactions in allergic consumers

    Reduces the risk of costly allergen-related recalls

    Demonstrates strong product control under BRCGS Clause 5.3

    Reinforces consumer trust and brand credibility

Support Tools Available

Food Safety Systems provides:

  • Allergen risk assessment templates

    Allergen matrix and SOP templates

    Label review forms and training materials

    Internal audit checklists for allergen control