Debate: Allergens vs Pathogens

Interested in hearing opinions from the group on which of two senarios they would prefer and most importantly, the why. If you were a food safety manager and had to rely on sanitation alone to remove either a known pathogen or an allergen (no labeling protection) from a production line. Which would you prefer? Both have distinct challenges and I don't think thier is a "right answer" but would love to hear what other profressions think.
Happy New Year all!

Interested in hearing opinions from the group on which of two senarios they would prefer and most importantly, the why. If you were a food safety manager and had to rely on sanitation alone to remove either a known pathogen or an allergen (no labeling protection) from a production line. Which would you prefer? Both have distinct challenges and I don't think thier is a "right answer" but would love to hear what other profressions think.
Happy New Year all!

I will prefer the Allergen, it will take less time and effort to detect and control it.

Doesn't look like there is much discussion but I figured I would add a couple points.
To Josegolden's point above, the detection does take less effort if an analytical test kit exist and results are available much quicker so again I agree if the test exist for the allergen in question. Just a number of bullet points: My concern with

• allergen cleaning is that sometimes is has to be done in dry (or preferably dry) areas and water cannot be used as one would like; making the removal of all allergen protein more challenging.
• sanitizer has no effect on an allergen,
• a “kill step” doesn't exist with allergens
• processing changes allergen proteins creating testing questions
• allergens does’t grow/spread as a pathogen is capable
• pathogens can create a biofilm.
• Fair statement? I believe that on average and we are talking small amounts, a human can possibly consume more of a pathogen without adverse effects (unless immune compromised) than someone who is allergic to an allergen. Most healthy adults' immune systems can kill small and differing quantities of pathogens. Infection/adverse impact takes longer, antibiotics exist.
• Are regulatory agencies testing for allergen carryover at all? And if they found a trace, my understanding of code is that it would not necessarily force a recall since there isn’t a zero tolerance as in the case of the regulation of pathogens. Furthermore, there is plenty of testing going on for pathogens by regulatory agencies but on not for allergens. Even if a detectable level of allergens was found it is my understanding that the FDA allergen regs would not force a recall. The downside of FDA’s lack of action concerning allergen and cross contact labeling.

Hopefully these comments spur more interest and comments.

Hi Nathan,

Very interesting post. There's a lot of ground that be covered in discussing your question as to what's preferable to deal with from a food safety point of view. So much depends on the product/risk level, use of dedicated vs. non-dedicated processing equipment, regulatory laws where your company operates, and on and on.

Personally I view both allergens and pathogens to both be huge issues. Either can be the root cause of recalls, or even worse - adverse health effects of our ultimate customers - the comsumer. In the U.S. allergens can be particularly difficult and frustrating to deal with in my industry, basically dry foods with many, many finished products, five allergens, and non-dedicated processing equipment. Wet cleans are somewhat of a negative in that they introduce water to a low water activity process which can result in pathogen issues. However carryover is also an issue with allergens, and a number of steps need to be taken to reduce risk of introducing an allergen from a previously run allergen containing product into subsequent product that doesn't contain that/those allergen(s). Cascading scheduling is one way that this issue can be addressed (after a thorough wet clean, schedule (for example) a non-allergen product, then a product with one allergen (ex. wheat), followed by a two allergen product (ex. wheat and egg), and so on until the processing equipment needs another wet clean due to product buildup that exceeds the SSOP limit.

Pathogens are, as pointed out, a completely different animal (no pun intended). Different preventive measures need to be considered, such as supplier approval (risk analysis that would include supply history, odds of microbial contamination of an ingredient, etc.), random testing of at-risk raw materials, a testing program for finished goods that may be considered by risk analysis to possibly carry a high micro load, etc.

Anyway, good subject and ultimately both allergens and pathogens are huge issues for the food industry around the globe.

Regards,
esquef