Scoops for Non-Allergen Ingredients
Hello, I work for a dry blend manufacturing facility. We handle 4 different allergens. We use colored coded scoops for scaling allergen and stainless-steel scoops for non-allergen ingredients. In our last BRC audit, our auditor suggested we review our process of using the same scoop for non-allergen ingredients, i.e, salt in sugar. We can scale up to 20 ingredients at a time. We do use separate scoops for odor, color, etc. (characteristic base). We consider using the same scoop for non-allergens to be an incidental additive.
What does everyone else do?
Your system sounds fine to me.
Sounds like you have a meddling Auditor.
No reason to muck up a good process.
As an aside, Audutors are not supposed to make suggestions or be consultants or tell you you should review something.
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What does everyone else do?
Mostly following the 'laboratory style' measurements approach. Pour out of the container, don't insert things into the container to extract material unless the instrument inserted is clean.
For most small scale ingredients we're pouring into a small vessel on a scale, then transferring that to a mixing/blending vessel.
If I'm understanding correctly, your process is using a single stainless scoop to scoop from multiple different non-allergen ingredients? Scoops were super common in my spice/dried veg plant as we established blends. I can see this both ways: relatively harmless if the ingredients are all dry and not super dissimilar, and generally known to be safe from micro issues.
But the auditor had a point that the cross-contamination factor isn't zero. If you were to receive one bad batch of an ingredient, scooped it first, then used that scoop on another bin or case of another ingredient, you've introduced contamination into your raw that could linger through following lots. Depending on how careful your employees are or are not when scooping, I could envision seeing a scoop not being fully emptied from one ingredient before it's thrust into a second ingredient (meaning now your package of raw salt has some sugar into it via carelessness).
You could do your own risk assessment to figure out if you should keep this process going. The fact your program calls for different colored scoops for allergens is an acknowledgement that residue transfer is a potential hazard. Justifying scooping salt and sugar from their raw bulk containers with the same scoop isn't impossible, but it'll forever raise eyebrows with some.
I would continue with your current process and use an assigned scoop for each ingredient. This makes sense per your comment on color, odor, etc. and as stated above there is the human factor of left over materials when scoping between ingredients and if there is an issue this could make matters worst. The risk is low to use the same scoop, but your current process seems to be a best practice already.