Allergen Environmental Monitoring

Transcription

1 Allergen Environmental Monitoring Douglas L. Marshall, Ph.D., CFS Chief Scientific Officer Eurofins Microbiology Laboratories Texas Association for Food Protection Annual Meeting Austin, TX June 14,

2 Eurofins Mission is Health and Safety Food #1 worldwide Environment #1 worldwide Pharmaceuticals #1 or 2 worldwide Our Mission: To contribute to global health and safety by providing our customers with high-quality laboratory and advisory services while creating opportunities for our employees and generating sustainable shareholder value 2

3 Our U.S. Presenc e Strategically located throughout the United States for Food, Pharma, and Environmental testing FO OD PHARMA ENVIRONM ENTAL 23 labs, 2 service centers Over 7,000 customers Service centers in IA and PA 3

4 Guidance FDA FSMA SEC HAZARD ANALYSIS AND RISK-BASED PREVENTIVE CONTROLS (4) the preventive controls implemented under subsection (c) are effectively and significantly minimizing or preventing the occurrence of identified hazards, including through the use of environmental and product testing programs and other appropriate means SQFI Guidance RE: Allergen Cleaning and Sanitation Practices 4

5 Allergens Within FSMA Allergen control targeted specifically within FSMA (GMPs and PC) Preventive controls required when allergens are in the facility Sanitation PC at change over Allergen PC Label accuracy at receipt or development Correct product with correct label at packaging 5

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7 Allergen Failures Leading to Recalls Formulation failures Rework control failures Cleaning failures Packaging and labeling failures Overuse of allergen warning statements on labels limits consumer choice. Such declarations are frequently ignored if allergenic food or ingredient is not listed as an ingredient. 7

8 Allergen Cross Contamination Shared harvesting sacks Shared transportation vehicles Shared processing equipment Allergenic carriers/flow aides Mislabeling 8

9 Intentional Adulteration? Allergies Peanut allergy warning: Traces found in ground spice, FDA says TODAY Feb. 19, 2015 at 8:37 PM ET Hundreds of products are being pulled from store shelves after traces of peanut were found in ground cumin spice a life-threatening danger to some people with peanut allergies 9

10 Food Allergen Control Program Training of processing and supervisory personnel Supplier control program for ingredients and labels Product label review and label usage and control Validated cleaning procedures for food contact equipment Prevention of cross contact during processing through measures such as: Scheduling of production runs Control of rework Use of dedicated production lines Equipment design and utensil use 10

11 Preventing Allergen Cross Contact Thorough cleaning using validated procedures Traffic control through facility mapping personnel and equipment to know where allergens are likely to occur Segregation of allergen-containing and allergen-free ingredients, products, utensils, equipment, and personnel Air and dust control use filters and avoid high pressure air hoses Water control to prevent wash water contamination 11

12 Sanitation for Allergen Removal Must have specific SSOPs defined Changeover from allergens to non-allergens Allow for adequate cleanout between runs Disassemble and manually clean equipment that cannot be cleaned thoroughly in place Properly clean accessory tools or equipment (i.e., scoops, bins, hoppers, etc.) Dedicate equipment that is difficult to clean Use alternative cleaning measures where wet wash is not viable e.g. sugar or salt flush Minimize the use of air as a cleaning aid 12

13 Examples of Process Changeovers Wet sanitation Full sanitation (detergent, rinse, sanitizer) Abbreviated sanitation steps (only water or water + detergent) Dry sanitation Scrap, vacuum, and physical removal of larger bits Try not to use air Product flush Flush with inert substance to absorb allergen materials (sugar, salt) Flush with actual product, identify by time or weight amount of flush needed 13

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15 Why Test for Allergens? Brand protection and liability reduction Regulatory expectation Validate effectiveness of critical control point interventions such raw material and ingredient receiving, and labeling Validate effectiveness of environmental control programs Validate purchase specifications by you or your customers Routine verification activities Compliance investigations 15

16 Cost of Not Testing Potential for injuring or killing your customer Intrinsic and extrinsic costs associated with recalls Facility closure and loss of business Damaged brand reputation No liability protection in fact liability increases due to lack of prudence 16

17 Verification and Validation Validation proving that cleaning and sanitation program removes allergens or reduces allergens to an acceptable level on equipment surfaces Must use an allergen-specific test for proof Verification once program has been validated as effective, manufacturer must verify that the validated program is used every time Visual observation with written record Protein test of surfaces ATP tests are not protein-specific and may not be appropriate 17

18 Allergen Control Plan Allergen management plan should be included as part of a prerequisite program, rather than being seen as a critical control point in terms of HACCP The initial cleaning validation should be conducted at least two times to ensure consistent removal of allergens The validation should provide a worst case scenario, for example by focusing on manufacture of products containing allergens at high levels, followed in the schedule by products not containing that allergen/and with sampling from areas that are hard to clean 18

19 Validating Allergen SSOP If the product containing the allergen or cleaning regime changes (time, cleaner concentration, cleaning chemical, temperature), or if the configuration of the line is altered, then the effectiveness of cleaning must be validated again To confirm the validation, it is suggested that the validation exercise be repeated periodically, but at least once per year to ensure continued allergen control If formulation contains multiple allergens, then allergen at the highest concentration should be targeted for testing 19

20 Examples of Validation Strategies Surface Sampling (Opened System) After process change over has occurred, prior to production, use an allergen specific swab to ensure that allergenic protein has been removed Product Testing (Closed or Open System) After a process change over has occurred, use a product testing program that selects first product produced to test for specific allergen protein, place product on hold until results available Product Testing (Closed System) After allergen product is run, flush system with inert substance (salt), use sampling program to test salt for specific allergen protein 20

21 Surface Sampling Validation Process 1. Run the formula with allergen included 2. Test the dirty equipment for the target allergen (positive control) 3. Perform the documented process-change over 4. Perform verification activities to determine if change over process was properly followed 5. Perform ELISA-based, protein-specific allergen test on equipment surfaces 6. If non-detected, process is validated 7. If protein is detected, change over process must be revised Source: 21

22 Food Allergen Testing Finished product testing may not be an effective validation method for cleaning commercial test kits LOD is ppm If mixed allergens are present, test choice may be for greatest risk allergen, allergen in greatest concentration, or allergen most difficult to remove. Ex. milk proteins in chocolates, caramel, or cooked eggs Alternately, test for allergen at least concentration when in presence of an abundant allergen. Ex. peanut butter in presence of larger amounts soy flour 22

23 Controlling Allergens in the Environment Map entire process to identify steps where controls can be applied Set allergen limits for what is acceptable/unacceptable Establish monitoring procedures ingredients, wash water, swabs, end products Determine corrective actions should limits be exceeded Prove effectiveness of corrective actions Keep records Periodic reevaluation of allergen control program 23

24 Sources of Allergens in the Environment Cross contamination of an ingredient with an allergen before or after receipt Accidental addition due to formulation error Cross contamination from an allergen-containing product Comingling of raw agricultural commodities during harvesting, storage, and primary processing is common Allergens may not be uniformly distributed in the environment è importance of sampling plan 24

25 Allergen Mapping Shared equipment Scheduling allergen free before allergen containing Potential for ingredient substitution Cross contamination issues conveyors, pipes Rework Labeling Effectiveness of cleanup to remove allergens Segregation people, equipment, supplies 25

26 Written EMP Plan Identify sampling sites - use facility grid - random rotation among grids - routine selective sampling of high risk sites Frequency of sampling Number of samples Sampling procedure Test method Corrective actions 26

27 Where to Sample? Sample equipment that is used for both allergen-free products and allergen-containing products Identify areas that are easily contaminated by employee traffic patterns and behaviors Compressed air and dust movement Direct product contact surfaces are most important Areas where product is exposed to the environment and before package closure are critical 27

28 Zone 1 Surfaces where product is exposed to the environment before final package closure Tables Conveyor belts Buckets Fillers Hoppers Utensils Employee hands and gloves 28

29 Zone 2 Areas in close proximity to zone 1 areas Enclosed equipment Vacuum cleaners Brooms Dust collection areas 29

30 What Samples? Finished product Product residue Food-contact surfaces Non-contact surfaces Air Water 30

31 Note on Swabs & Sponges Use sponges/swabs recommended by kit manufacturers Make sure sponge/swabs are free of allergen protein that you are targeting (tryptone/peptone/soy) 31

32 Key Points for Sample Collection Don t cross contaminate your sample with dirty hands, dirty attire, or dirty sample collection devices Make an effort to find hard-to-clean areas Use results to educate employees 32

33 Testing Frequency History and trends Features of the plant Type of product and volume Plant layout Product flow 33

34 Sampling Frequency When first starting, sample numerous sites and use large surface areas to gauge degree of contamination and identify potential problem areas Increase frequency when: Ingredient changes Construction events Equipment installation Whenever unwanted allergens are found 34

35 Method Selection Don t make it harder than it has to be Sample for the type of allergens expected in the room Choose those that are most abundant Choose those that are most difficult to remove powders & pastes Validate the method used on dirty equipment before cleaning to make sure it works for the target allergens Select appropriate equipment/tools recognized by industry to perform sampling 35

36 Method Selection ATP kits may be useful to monitor cleanliness but do not directly measure allergens ELISA-based methods are specific for specific allergenic protein ex. Kit for milk protein casein will not detect whey protein β-lactoglobulin Finished product testing for allergens or source material DNA is the ultimate validation step 36

37 Eurofins Allergen Testing ELISA Most commonly used, commercial kits available Detect actual allergen Occasional difficulty measuring fermented protein (e.g. gluten-free products) Difficulty measuring cooked protein Difficulty measuring protein in high lipid content products Not all allergenic proteins are measurable Eurofins is ISO Accredited US, Canada, EU, and Japanese regulated allergens 37

38 Eurofins Allergen Testing PCR Detect nucleic acid from allergenic source material Useful when ELISA methods not available (e.g. fish protein) Good for measuring cooked protein Useful for confirmatory tests Does not directly measure protein (e.g. difficult to translate to ppm allergen) 38

39 Allergen Test Targets 39

40 Proteins Can Denature During Food Processing 40

41 Denatured Proteins Can Cause Antibody-Antigen Reaction Failure 41

42 Food Processing Affects Ag/Ab Reaction Heating cooking, pasteurization Fermentation Acid/Alkali Treatment Hydrolysis hydrolyzed vegetable protein, fish sauce, soy sauce Protein Coagulation Protein Complex Formation Extraction Difficulties 42

43 Matrix Affects Protein Recovery Material Allergen Recovery (%) Ice Cream Egg 100 Bread Egg 100 Pasta Egg 100 Ice Cream Walnut 77 Cookies Walnut 63 Milk Chocolate Walnut 17 Marceau et al., 2013 AOAC Annual Meeting 43

44 Method Selection When allergenic proteins are denatured by heat treatment or fermentation, ELISA/Lateral Flow-based kits may not detect allergens DNA-based methods such as PCR can detect residual source material when protein detection is difficult PCR can detect source material when ELISA methods are not available Very low quantities of heat-processed allergenic proteins can be detected using LC-MS/MS Simultaneous multi-protein detection can be achieved by LC-MS/MS 44

45 Polymerase Chain Reaction 45

46 PCR Allergen Tests Celery Corn Finfish Peanut Pistachio Soy Walnut/Pecan Wheat Other types 46

47 Celery Clean Label Ingredient All Natural No Preservatives No Artificial Ingredients Cryptic functional ingredient as a source of nitrate/nitrite for processed meat use Used to replace nitrite in cured meats hams, bacon, deli meats, sausages, etc. Nitrite aids in formation of stable pink color Nitrite prevents Clostridium botulinum outgrowth in vacuum-packaged products 47

48 Apiaceae Family Cross Reactivity Plant PCR Reaction ELISA Reaction Celery + + Celeriac + + Leaf celery + + Carrot - + Parsnip - + Parsley - + Lovage - - Dill - + Anise seed - + Fennel - +/- Caraway - - Coriander - - Chervil - - Sandberg et al., 48

49 Cumin Adulteration: PCR vs. ELISA Sample Type PCR (Peanut DNA) ELISA (Peanut Protein) Ground Cumin Negative <2.5ppm Ground Peanut Shell Positive >20ppm Cumin w/ 10% Shell Positive >20ppm Cumin w/ 1% Shell Positive <2.5ppm Cumin w/ 0.1% Shell Positive <2.5ppm 49

50 PCR Won t Work When DNA is not present Oils Milk Egg Whites Food or ingredient contains PCR inhibitors Metals Lipids Proteins Need for differentiation Beef vs. milk Low ph can fragment DNA Chicken vs. egg Absence of correlation between presence of DNA and presence of allergenic protein 50

51 Corrective Actions Limit access to area Break down and inspect equipment Thoroughly clean and sanitize all equipment, surfaces, and tools in area Increase sample frequency Resample equipment and surfaces to determine if contamination is localized or widespread Monitor area around hot site to find source If preop inspection fails, re-clean, re-sanitize, and resample as needed Do not restart operations until all tests are negative 51

52 Corrective Actions Goal to achieve at least 3 consecutive negatives at contamination site Document corrective actions Create SOP to prevent reoccurrence If problem persists consider removal, replacement, or redesign of contaminated equipment 52

53 Thank you for the opportunity to provide this overview Eurofins Scientific, Inc. We look forward to working with you in the future