PCHA 10 (PCHA 10)

Natural Enrichment Industries SQF Food Safety Code for Manufacturing Document: 2.8.1 Allergen Management Policy Date: 12/23/2020 Revision: 3 Prepared by: SQF Team Approved by William M. Kuzma Responsibilities and Methods: In order to minimize the risk of allergen contamination in NEI’s TCP, various controls have been put in place to identify allergen risks associated with raw materials, packaging material, lubricants, lunchroom exposure, and shipping. The HACCP Team has performed risk analysis on the raw material (including raw material shipping), the manufacturing process, and the packaging material used in the plant. The determination of the team’s assessment is that the raw material (lime, phosphoric acid, acetic acid, and water) presents minimal risk insofar as the processing steps for the manufacture of each do not include any allergens on the list in Table 1. Table 1: List of 12 common allergens Milk Eggs Fish Crustaceans Shellfish Tree nuts Peanuts Wheat (including gluten) Soy Mustard Sesame Sulfites The manufacturers of raw materials and packaging provide assurance through vendor questionnaires that they protect their processes from allergens. The Shift Supervisors refuse delivery of incoming raw materials if a washout ticket is not present. The washout ticket verifies that the delivery vessel has gone through the process of removing residue in the tanker that may be potential sources of allergens. Other truck cleanliness checks further insure minimization of allergen risk potential. The procedures include: QCP 18-Incoming Raw Material-Lime QCP 19-Incoming Raw Material-Phosphoric Acid QCP 20-Acetic Acid Unloading Natural Enrichment Industries SQF Food Safety Code for Manufacturing Document: 2.8.1 Allergen Management Policy Date: 12/23/2020 Revision: 3 Prepared by: SQF Team Approved by William M. Kuzma The Supervisor of Sanitation and Safety performs annual allergen risk training. All manufacturing personnel, maintenance personnel, and lab personnel are educated on the sources of allergens, the importance of hand washing and lunchroom cleanliness in minimizing potential allergen contamination of the TCP. Training also emphasizes the hazards to at risk individuals that allergens present. Additionally, the Supervisor of Sanitation and Safety inspects lockers and removes food that has been stored and warns the employee of the allergen risk such behavior presents. Training records for allergen risk training are maintained by the Supervisor of Sanitation & Safety. The facilities contain no vending machines. The facilities do not store or handle any of the substances found in Table 1. The Inventory Control Supervisor examines vessels for outgoing loads, ensures that where applicable (bulk loads) the washout ticket is present, and approves the delivery of outgoing loads. Records for outgoing loads are found on F11.7.6 QCF 11 Finish Product Loading. The records are maintained by the Inventory Control Supervisor. The chief means by which allergens may enter raw materials would be due to foreign residues found in tankers or containers without washout tickets. Procedures QCP 18, QCP 19 and QCP 20, previously cited, provide instructions for handling (refuse to unload). Rework and finished product that is known or suspected to have allergen contamination is treated as reject material, is properly labeled as reject material, is segregated and eliminated. Special labeling is not required in the process for making TCP, since the raw material should never contain allergens and allergens are not stored in the facilities or used in the process. Likewise, special instruction for segregating and monitoring allergen containing products do not exist. Mops used for cleaning the break room are positively identified and forbidden to be used for general cleaning of the plant. Cleaning of the tabletops of the lunchroom is performed using disposable toweling. Natural Enrichment Industries SQF Food Safety Code for Manufacturing Document: 2.8.1 Allergen Management Policy Date: 12/23/2020 Revision: 3 Prepared by: SQF Team Approved by William M. Kuzma The break room is recognized as being the place where allergen cross-contamination presents the greatest allergen risk. Hand washing basins are provided either in (Herrin) the break room or in the immediate vicinity (Sesser) of the break room. Employees are annually instructed on the risk associated with lunchroom behavior. Since there are no allergens used in the manufacture of TCP, no special labeling requirements are known to apply. Likewise, label accuracy procedures and documentation are not available or required. Product trace procedures (mock recalls) are performed two times per year. The procedures generally apply and would be followed in the event of an allergen contamination event. Reworking of material known or suspected to have an allergen shall not be performed. Visitors, contract manufacturers, and suppliers, with respect to allergen risk, are expected to follow the GMP’s with the same rigor as the employees (no food or drinks, meals to be eaten in designated lunch areas only, wash hands after eating, etc.) Annually the allergen management shall be reviewed, and amendments made in order to keep the program current and effective. The food safety team shall review the Food Safety/HACCP program annually and reassess allergen risks associated with all levels of the manufacturing process as part of the review process. The allergen program will also be audited annual as part of the internal audit program. The above procedure shall also be applicable for the manufacture of pet food.

Food Ingredient