Cleanliness and keeping dairy products safe go hand in hand. And at a processing facility, that goes beyond preventing quality problems and eliminating potential contaminants in the environment. Allergens can become just as problematic for dairy processors if the wrong type of food makes its way into a product.
As Sani-Matic, Inc., vice president of sales and marketing Bryan Downer put it, repeatable, verifiable, traceable cleaning can help companies handle allergens before they become an issue.
Cleaning versus sanitizing
“It is important to understand that allergens are like a chemical contaminant rather than biological, so they don’t respond to neutralization or ‘kill’ processes, but rather typically must be physically removed,” Downer said.
The United States Food and Drug Administration (FDA) identifies the nine major food allergens as milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soy and sesame. Per the FDA, food allergies and other types of food sensitivities impact millions of US citizens and allergic reactions can vary from mild to life-threatening symptoms.
When residue or trace amounts of a food allergen make their way into a product, it tends to be the result of environmental exposure during processing or handling. Downer said a facility’s food safety plan should first identify all the areas where allergens could be present, and then make sure repeatable, verifiable and traceable actions are carried out to remove those allergens.
He said best practices for dairy facilities really come down to proper cleaning, and he made sure to point out that the words sanitizing and cleaning should not be synonymous, because most sanitization processes won’t eliminate allergen threats like they do with biological contaminants.
“Often sanitizers or other ‘kill’ processes are relied upon to remedy situations where cleaning is not consistent or reliable,” Downer said. “This is where focusing on the proper cleaning or removal of the allergens is critical.”
In order to best handle allergens, Downer recommended eliminating all potential for variability and increasing the active monitoring of the cleaning that takes place in areas where allergen hazards exist. For example, he called manual cleaning “fundamentally rife with inconsistency” and lacking true traceability.
He instead suggested using an automated cabinet washer, because with that technology the cleaning “recipe” is repeatable and comes with the added benefit of full traceability, with verification that can be accessed in real time.
Available approaches to handling allergens can be different for smaller manufacturers than their larger counterparts. Eric Garr, regional sales manager for Fortress Technology Inc., explained that larger processors will segregate production areas that handle known allergens when possible, but that may not be an option for smaller processors.
When separate production areas aren’t available, Garr said the emphasis must shift to hygiene and effective processes.
“In fact, where potential allergens are present or could be present in some sets of ingredients but not in others, cleaning must go well beyond normal hygienic requirements,” he said. “Even where heat processing is involved, allergens can still survive high temperatures.”
Among the several steps necessary for handling allergens in such scenarios, Garr added, are equipment cleaning protocols that are formalized and included in staff training. To make sure a food safety plan works, each cleaning process also must be verified and documented through regular testing – he said swabbing of critical control points should be scheduled to verify that specified areas are remaining allergen-free.
Additionally, Garr said all products containing known allergens should have clear and legible labels to prevent potentially life-threatening allergic reactions and ensure regulatory compliance.
In facilities that use gravity metal detection systems for powders and particulates, Garr said, product residues that potentially include allergens can be “especially troublesome.”
“Routine risk assessments and audits help to control the introduction of foreign material into products,” he said. “External eyes provide a different perspective. Many internationally recognized audits follow set standards and provide a complete 360-degree review.”
Common problem areas
Avoiding allergen-related complications in a facility is a must, especially when undeclared allergens in products routinely lead to food recalls.
Within the dairy supply chain, Garr said companies can reduce the risk of consumer exposure to allergens by taking the greatest care when sourcing ingredients and by auditing suppliers.
The Center for Dairy Research recommends that dairy processing companies ask their suppliers each year for an allergen statement on all products that are used. Per CDR, such statements should include all allergens present in the supplied product, as well as a notice if the product is made on the same line as other allergens.
Downer credited the dairy industry with traditionally doing a good job of keeping its fluid processes both well designed and cleanable. For dairy processors, he said allergen problems most commonly are encountered with processes downstream, such as handling, cutting, filling and packaging.
He said those often are areas where a variety of products can come in contact with common equipment. Plus, that equipment tends to be difficult to effectively clean in place. Weight scales, filling machines, cutting blades and transfer trays came to mind for Downer as examples of equipment used for multiple types of products.
“The easiest solution might be to have dedicated equipment for the allergen products, but that is not always practical or feasible,” Downer said. “This is where first selecting the correct equipment that is designed to be easy to disassemble as needed and cleaned preferably using automated methods is best. If the equipment is already in place, have a third-party cleaning audit conducted where proper cleaning procedures can be evaluated and implemented.”
Garr advised that taking shortcuts that make cleaning procedures faster is not only risky, but bad business.
“If equipment surfaces are not cleaned properly between batches, cross-contamination can occur, introducing an allergenic ingredient to a product that should not contain it,” Garr said. “To avoid cross-contamination, dairy processors should use separate equipment, utensils and storage areas for allergenic ingredients. They should also establish a cleaning and sanitation schedule to prevent cross-contamination.”
Because cleaning manufacturing and processing machinery is not a contactless task, Garr said, Fortress began developing “smarter designs to enhance hygiene and safety.”
The company’s newest range of food inspection systems eliminate the use of tools and implement “an innovative conveyor with a very robust de-tensioning feature to facilitate deeper and faster cleaning by trained operatives,” he said. To improve line efficiency, the equipment also instantly restores belt tension and alignment when clipped back into place after maintenance and cleaning, he added.
Mislabeling is another potential pitfall for dairy processors. Garr noted that a finished product label that does not list an allergen can have legal consequences for companies, due to the serious health issues consuming certain allergens can have for some consumers.
“Failure to properly identify allergenic ingredients can occur if a dairy processor does not carefully source their ingredients or does not thoroughly review supplier documentation to identify potential allergens,” he said. “To avoid this issue, dairy processors should carefully source their ingredients from reputable suppliers and review supplier documentation to identify any potential allergens.”
The FDA enforces regulations that require companies to list ingredients on packaged foods and beverages, and more specific labeling requirements are in place for substances that cause allergic or hypersensitivity reactions.
Because milk is a common food allergen, cross-contamination must be prevented during the handling and processing of products in facilities where both dairy and non-dairy products are made, Garr said.
To avoid major problems with allergens, he noted, some companies have separate production lines for dairy-free products, which helps prevent any milk particles from entering non-dairy products during the processing.
Employee training at facilities is crucial in the dairy industry. Garr said workers must receive specialized guidance on allergen management, such as the identification of potential allergens, appropriate cleaning procedures and the use of protective gear to prevent cross-contamination.
Garr considers most dairy processors to be “strong custodians of hygiene and safety practices,” and said allergen control often comes down to common sense. To help with that cause, he said Fortress makes a range of pipeline, conveyor and checkweighing inspection equipment suitable for the industry’s hygiene requirements.
Similarly, Downer said other industries are now moving to the more stringent equipment standards that dairy always has followed, in part to address allergen concerns.
“In general, the dairy industry is better positioned to handle the concerns of allergens than other food industries due to the years of development and attention to cleanability.”