BRC 5.3.2 - assessing the allergenic risk of items in vending machines

We do not have any allergens on site, other than what is in our vending machines. 

No allergens are used in any capacity in our process...

The only introduction of allergenic material would be through people at break times, and not washing their hands.

So, do you all think i should list what we have in our vending machines, and to consider those an allergenic risk?

Our employees wash their hands before entering production as well as wearing two pairs of gloves. one rubber and one cotton.

You need an allergen control program for your vending machines. 

Hands are not the only possibility - think about sneezing, coughing, carrying food into the work place.

Our clients for SQF have signs posted on all of the vending machines showing what allergens are present and have written programs in place.

We do not have any allergens on site, other than what is in our vending machines. 

No allergens are used in any capacity in our process...

The only introduction of allergenic material would be through people at break times, and not washing their hands.

 

So, do you all think i should list what we have in our vending machines, and to consider those an allergenic risk?

Our employees wash their hands before entering production as well as wearing two pairs of gloves. one rubber and one cotton.

Hi LSB,

People have been "dinged" for this potential hazard in older posts. IIRC peanuts are quite popular.

If there are allergens you are particularly concerned about then you may also find it useful to turn also agree a slightly restricted item list with the company stocking the vending machines - we have a nut/peanut free site and have a written agreement with the suppliers of these types of item to not deliver anything containing nuts/peanuts. If you're setting this as a new requirement then there may be a learning curve so you'll need to monitor it, but they do learn and particularly if you dispose of their stock for violating the agreement...

In terms of listing everything for your risk assessment, the only way you'll realistically be able to do this will be by allergen category - for example, our assessment is done on the basis that staff lunches and snacks etc may contain any of the 14 EU allergens with the exception of nuts and peanuts.

In terms of the potential routes of contamination, the level of risk will depend on the nature and effectiveness of your training program and general levels of adherence to site hygiene rules, so whilst it's possible to e.g. sneeze peanut residue into your products it's hopefully very improbable that anyone would actually do this.

IME it's a really popular area for BRC auditors to look at and can be a source of an easy non-conformance - every year they like to have a bit of a dig around in the refrigerators used by the staff for their lunches (as do we, as part of our own internal audit program ;) ) but I've seen them go as far as asking for gloves and poking around in the rubbish bin in the break room to see if anyone had eaten and then disposed of anything on the banned list!

Thank you all for the feedback.

We do not have any refrigerators on site. We just have vending machines with a few of the Big 8 US allergens. I think we would start to paint ourself in a corner if we consider sneezing a possible transmission of an allergen, and trying to find ways to mitigate someone sneezing would be......a little difficult. 

I will come up with some sort of allergen mitigation protocol that we already have in place. Our product and facility is "low risk" so i dont think banning a certain food group i.e. allergen would be needed. 

Thank you all for the feedback.

We do not have any refrigerators on site. We just have vending machines with a few of the Big 8 US allergens. I think we would start to paint ourself in a corner if we consider sneezing a possible transmission of an allergen, and trying to find ways to mitigate someone sneezing would be......a little difficult. 

 

I will come up with some sort of allergen mitigation protocol that we already have in place. Our product and facility is "low risk" so i dont think banning a certain food group i.e. allergen would be needed. 

I think you will find that, from BRC's POV, you will no longer be able to  claim that you have an allergen-free site. But perhaps that is not anyway important in yr case.

There are various informative Forum threads on this topic for BRC/SQF,  just do a search for "vending".

The obvious solution would be to ban pollen, pepper, and feathers (oh my!) The list just keeps on growing!

I think we would start to paint ourself in a corner if we consider sneezing a possible transmission of an allergen, and trying to find ways to mitigate someone sneezing would be......a little difficult.

I put up signage and posters regarding allergens, including on the vending machine, along with initial and regular allergen training. It may be because we are a very low risk facility, but I don't ban any allergens in our vending machines. My stance is that banning them in the vending machine would be useless, as banning the other obvious route of employee lunches would be an eternal uphill battle. How do you plan on enforcing a ban on what employees are allowed to bring in their lunchbox? Further, if you can train employees so meticulously as to lookout for trace allergens in all their food items, why not just train them to wash their hands extra careful?

My stance is that banning them in the vending machine would be useless, as banning the other obvious route of employee lunches would be an eternal uphill battle. How do you plan on enforcing a ban on what employees are allowed to bring in their lunchbox? Further, if you can train employees so meticulously as to lookout for trace allergens in all their food items, why not just train them to wash their hands extra careful?

A no nut/peanut policy is not uncommon on nut/peanut free sites and in my experience is quite feasible to enforce if the communication, training and monitoring is done well and a good staff culture is in place. Trying to ban all major allergens in staff food would be unrealistic of course and in terms of consumer risk would be unnecessary, whilst banning one or two high risk allergens that cant easily be excluded from a lunch box would further reduce the chance of contamination, in addition to existing hygiene controls like hand washing.