EthicalHub

HACCP & PRPs

Allergen management plans for mixed production sites

The matrix, segregation, scheduling, changeovers and labels that keep undeclared allergens out of your products.

The short answer

An allergen management plan starts with an allergen matrix of every ingredient and product. From it, you segregate allergens in storage and production, schedule allergen-free runs first, use validated changeover cleans between products, and check every label against the recipe. Precautionary statements come last, and only after a risk assessment such as the Allergen Bureau’s VITAL program.

The plan

The six parts of the plan

1. Allergen matrix

Every raw material and product against every allergen. Updated when a recipe, supplier or specification changes.

2. Supplier control

Allergen declarations from every supplier, and a rule that suppliers tell you before they change a formulation.

3. Segregation

Separate, labelled storage, and dedicated utensils or colour coding for allergen ingredients.

4. Scheduling

Allergen-free products first, then increasing allergen load, so fewer cleans are critical.

5. Changeover cleaning

A written clean between allergen and non-allergen runs, validated once and verified every time.

6. Label control

The right label on the right product, checked at the start of every run and after every label change.

Start here

Example allergen matrix

MaterialMilkEggWheatSoySesame
Wheat flour✓
Butter✓
Sesame seed topping✓
Bread mix (supplier)✓✓
Product: seeded loaf✓✓✓✓

Illustrative only. Your matrix lists every allergen your products must declare under the Food Standards Code.

Changeovers

Validating and verifying changeover cleans

Validation proves your method works: run the clean, then test surfaces or the first product after it with an allergen-specific test, such as ELISA or a lateral flow kit for that allergen. Do it for each allergen and line, and repeat it when the product, equipment or method changes.

Verification proves it was done this time: a visual check and sign-off at every changeover, plus routine allergen tests on a schedule you set. Keep both. An auditor will ask for the validation study and the daily sign-offs.

Labels

Precautionary labelling: last, not first

“May contain” is not a substitute for controls. Many Australian manufacturers use the Allergen Bureau’s VITAL program, a voluntary risk assessment that uses reference doses to decide whether cross-contact justifies a precautionary statement. Where it does, VITAL uses one wording: “May be present: allergen”.

Mandatory allergen declarations follow the Food Standards Code and plain English allergen labelling. See the PEAL labelling checklist.

Where EthicalHub fits

Allergen records that keep up with changes

In EthicalHub, supplier allergen declarations sit with each supplier’s certificates, changeover cleans are signed off on the floor, and a failed verification opens a corrective action. Every plan includes supplier management and corrective actions, from $69 a month per site.

See it with your own products

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Questions

Allergen management: common questions

What is an allergen management plan?
A documented set of controls that stops allergens getting into products where they aren’t declared. It covers which allergens are on site, how they are stored and scheduled, how equipment is cleaned between products, and how labels are checked.
What is an allergen matrix?
A table of every raw material and product against every allergen, showing which contain each one. It’s the starting point for scheduling, cleaning and labelling decisions, and it must be updated whenever a recipe or supplier changes.
How do I validate an allergen changeover clean?
Show that your cleaning method removes the allergen to an acceptable level, usually with allergen-specific tests such as ELISA or lateral flow kits on surfaces or the first product after the clean. Repeat the validation when the product, equipment or method changes, and verify it routinely.
When can I use “may be present” labelling?
Only after a proper risk assessment, not as a blanket cover. Many Australian manufacturers use the Allergen Bureau’s VITAL program, which uses reference doses to decide whether a precautionary statement is warranted and sets a single wording: May be present: allergen.

Every allergen, accounted for.

Declarations, changeovers and checks, recorded as you go.

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