People & Training

Staff should be trained, and where appropriate assessed, in their understanding food allergens, the risk to consumers with food allergy, the identification of cross contact allergens and the management of food allergens.

Training in food allergens should be provided to staff from many parts of the business, including management where appropriate, and from all production shifts. It can include and is not limited to raw materials procurement and handling, cleaning, equipment, maintenance, production, labelling and product development. Training records (including certificates of registration and qualifications) should be kept and maintained for all staff.

Case Study

Jack worked for a company that made gourmet sausages. He was responsible for conducting allergen risk reviews to understand the allergen status of the five sausage varieties produced. With support from his management, Jack had arranged for some of the staff to attend allergen training.

Part of the training included a general introduction to food allergens using a freely available training presentation from the internet, other training was more comprehensive and designed for the staff that worked in production, quality, and product development.

Although the business had strong good manufacturing practice principles, some positive changes were made after the training. Notices were put up explaining the importance of washing hands after working with raw materials containing allergens, processes were improved to reduce the procurement of raw materials containing cross contact allergens, and the cleaning staff identified possible inconsistencies between shift changes and implemented improvements.

These changes to business practice reduced the risk of allergens unintentionally being incorporated into the sausages and helped Jack be more confident in understanding the allergen status of the sausages.

• Include site maintenance teams within training.
• Provide generalised allergen training for site-wide awareness.
• Don’t forget to train high turnover staff, contractors (including cleaning staff), or other part time staff.
• Provide specific instructions for the control of allergens to those directly handling the ingredients or working within the processing areas.
• Ensure allergen related communications required for shift changeovers are effective.
• Maintain revision and updates to production SOP’s, training records, and reference materials.
• Explain the use of appropriate signage and of colour coding.
• Provide clear instructions on waste management and uniforms.
• Explain the importance of careful attention to clearing out old packaging and label verifications.

Management commitment and support
Senior management should support formal allergen training of their staff so that they are aware of allergen risks and the processes in place to control them. Management should also provide the resources required to conduct an allergen risk review and to develop, implement and comply with the AMP.

Cross functional team
An allergen risk review and the preparation and maintenance of the AMP involve many people within the business. The cross functional team should represent people from all parts of the business who understand the manufacturing process and how allergens can impact.
The team may include a representative from and is not exclusive to: –
• Raw Material & Supply Chain Management
• Raw Material Receipt, Storage & Handling
• Product Development
• Production Design & Scheduling
• Operations, Engineering & Cleaning
• Marketing
• Quality Assurance
• Labelling

New staff, contractors, casuals and visitors
Personnel on site should comply with all GMP rules – this includes contractors, visitors and casual/temporary/new staff. Copies of the rules should be provided to all personnel entering a site.
A dedicated host should be assigned when employing contractors or welcoming visitors, and the host should be responsible for assuring that they know and comply with GMP rules. Visitors should always be accompanied by their host or undergo an induction process which covers off allergen risk management.
A site induction process should be in place to ensure that the company/site allergen management procedures are advised and acknowledged. Records of induction to the site should be maintained.

Clothing and personal protective equipment (PPE)
Provision of dedicated work wear (including PPE) should be considered for use in areas handling specific allergens or where a high risk of cross-contact through clothing exists. Such work wear should be restricted to working areas (i.e. not in canteen area or external areas). Clothing controls should be in place for staff moving between allergenic and non-allergenic zones.

Staff movement
Staff movement between allergenic and non-allergenic zones in the manufacturing facility should be reviewed and controls implemented to mitigate allergen related risks. Such controls might involve PPE change or entry and exit via a dedicated route.

Staff facilities
Staff facilities should be sufficiently separated from ingredient storage and production areas. Controls to prevent allergen cross contact should be in place for food that staff bring to the facility This could include storage arrangements for food bought in by staff, contractors or visitors (e.g. snacks and lunches) that is not intended to be used in production. Storage and consumption of foods should be separate to the manufacturing area.

Reporting suspected allergen control breaches
Staff should be encouraged to report any suspected allergen management breaches to the relevant area supervisor and to suggest possible improvements.

Management commitment and review – A documented AMP should be in place which is authorised by senior management and communicated to all staff. Authorised personnel are responsible for development and implementation of AMP which should be reviewed at least annually or when changes are made.
People Management – Documented procedures for the management and control of personnel that includes personal protective equipment (PPE), personal hygiene, meals, movement, facilities, staff changes and visitors should be in place.
Training – The AMP will include processes where new staff are provided with induction training and current staff undertake annual refresher training in allergen management.