Allergen management: may contain labels, supplier changes and testing

Question 1

When should we use a "may contain" statement?

Accepted Answer

Precautionary allergen labelling (PAL) is not a substitute for good controls. It can only be used when a genuine risk of cross-contamination remains after all reasonable controls are established and effected. Before using PAL, a manufacturer still needs to ensure: all allergens on site are identified, including raw materials and rework points where there is a cross-contamination risk are assessed, e.g. shared equipment, scheduling, cleaning, airborne transfer, traffic routes (people, products, raw materials, equipment etc.) allergen cleaning is validated to confirm the efficacy of allergen removal The use of “may contain” is only permitted where a real residual risk can’t be eliminated even in the presence of effective and properly implemented controls. Adding it "just in case" reduces its value to allergic consumers and can be challenged by customers, retailers and certification bodies. Base the decision on a documented allergen risk assessment. In BRCGS Food Safety Issue 9 this sits in section 5.3 (management of allergens).

Question 2

How do we catch a supplier changing an ingredient without telling us?

Accepted Answer

It happens: we've seen a bulking agent quietly switched to one containing an allergen, noticed only from a slight change in colour or texture. Specifications are only formally reviewed periodically (the BRCGS Food Standard says at least every three years, clause 3.6.4), or when something prompts it. A practical fix: when you confirm each quote or repeat order, ask the supplier to confirm (even by email) that the specification hasn't changed. Combined with checking the spec is still right for each purchase, that covers both angles.

Question 3

How do we prevent cross-contamination in production?

Accepted Answer

Segregate allergen-containing and allergen-free ingredients in clearly labelled storage; clean thoroughly between runs, with dedicated tools where needed; train staff in handling, PPE and handwashing; and use audits and testing to spot problems early.

Question 4

What's the best way to train staff on allergens?

Accepted Answer

Combine hands-on training with clear communication: cover the basics, use real examples, put up posters and checklists (the canteen is a good spot), include allergens in annual refresher training, use quick quizzes, and check procedures are actually followed.

Question 5

Are rapid allergen tests good enough?

Accepted Answer

Their big advantage is knowing now, rather than waiting for a lab while production continues. They cost more per test, but scrapping or recalling product costs far more. Certification programme owners expect lab testing to support validation studies, yet rapid test kits are validated rigorously too, and some labs use them. If your validation is designed based on risk, you should be free to choose the most relevant methods, often a combination of both. Our BRCGS Validation & Verification course covers designing a risk-based validation study.

Question 6

We had a major NC for allergen clean-downs. Swabs are scheduled but results won't be back before our audit. Is that a repeat NC?

Accepted Answer

If the original NC came from an internal audit and the corrective action was to add swabbing to the schedule, and the swabs were done on time, this is more likely an open corrective action than a repeat NC. Show the auditor the swabs were taken, samples sent and the schedule followed. The auditor will also ask why swabs weren't being done before. Have your root cause and preventive action written up: who owns the schedule, who signs it off, what changed in the procedure or training. And ask the lab for a preliminary result by email; most will help if you mention the audit. Section 3.7 of Issue 9 expects corrective action to address the root cause, not just the symptom. More short videos on our STC & QTC Explains channel: https://youtube.com/@stcandqtc Learn more: BRCGS Food Safety Issue 9 Sites Training , HACCP & Food Safety courses and the course calendar . For an allergen risk assessment review, contact QTC .

Allergen management: may contain labels, supplier changes and testing

Q: When should we use a "may contain" statement?

Q: How do we catch a supplier changing an ingredient without telling us?

Q: How do we prevent cross-contamination in production?

Q: What's the best way to train staff on allergens?

Q: Are rapid allergen tests good enough?

Q: We had a major NC for allergen clean-downs. Swabs are scheduled but results won't be back before our audit. Is that a repeat NC?