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
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✓ 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
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Assessment Activities:
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• 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:
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• Allergen risk assessment document
• Updated allergen matrix and flow diagrams
• List of allergenic raw materials with supplier specs
- • 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
- • Allergen risk assessment document • Updated allergen matrix and flow diagrams • List of allergenic raw materials with supplier specs
2. Establish Allergen Handling Procedures
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Control Measures Should Cover:
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• 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:
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• SOPs for allergen handling and cleaning
• Line clearance and changeover checklists
• Visual or color-coded identification systems
- • Segregated storage of allergenic ingredients • Dedicated equipment or cleaning protocols for changeovers • Scheduling strategies to minimize risk (e.g., allergen-to-non-allergen sequencing)
- • SOPs for allergen handling and cleaning • Line clearance and changeover checklists • Visual or color-coded identification systems
3. Verify Label Accuracy and Packaging Controls
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Label Control Actions:
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• Check all labels against the finished product formulation
• Implement label approval and verification procedures
• Ensure correct packaging is used every time
Evidence to Maintain:
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• Label verification records
• Final pack checks and label reconciliation logs
• Mock product labels with highlighted allergens
- • Check all labels against the finished product formulation • Implement label approval and verification procedures • Ensure correct packaging is used every time
- • Label verification records • Final pack checks and label reconciliation logs • Mock product labels with highlighted allergens
4. Train Staff in Allergen Awareness
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Training Should Include:
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• The “big 8” or regionally regulated allergens
• Cross-contact risks and control points
• Emergency procedures in case of allergen exposure
Evidence to Maintain:
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• Allergen training materials and attendance sheets
• Post-training evaluation or quizzes
• Annual refresher training schedule
- • The “big 8” or regionally regulated allergens • Cross-contact risks and control points • Emergency procedures in case of allergen exposure
- • Allergen training materials and attendance sheets • Post-training evaluation or quizzes • Annual refresher training schedule
5. Monitor, Audit, and Improve
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Ongoing Controls:
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• Internal audits of allergen storage and labeling
• Periodic review of allergen risk assessments
• Investigation and corrective action for allergen-related complaints
Evidence to Maintain:
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• Allergen audit results and non-conformance reports
• Updated SOPs based on findings
• Corrective/preventive action (CAPA) logs
- • Internal audits of allergen storage and labeling • Periodic review of allergen risk assessments • Investigation and corrective action for allergen-related complaints
- • 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 |
