An 8-Step to Allergen Management in Food Packaging for Food Safety Managers

Introduction
Food safety managers must be aware of the risks associated with allergens in food packaging. Contamination can occur from Food Contact Materials (FCMs), leading to serious health risks for consumers with food allergies. This guide outlines key considerations and presents an eight-step framework for effective allergen management in food packaging. 

Sources of Allergens in Food Contact Materials
The Packaging and Packaging Waste Regulation, effective from August 2026, will mandate minimum recycled content in plastic packaging across the EU. Many biodegradable and biobased FCMs are made from protein-based materials like milk, egg, soy, and wheat gluten, which can pose allergen risks. 

Common allergens in food packaging include soy, wheat, dairy, peanuts, and tree nuts. These allergens can come from various sources, including adhesives, additives, and lubricants. Recyclable pallets from other food industries, such as dairies, may carry residual allergens. Additionally, improperly cleaned pallets used for transporting food can lead to cross-contamination. 

Another risk arises when recycled materials are used in packaging. These materials may contain traces of allergens from previous uses, which can unintentionally transfer to new packaging. For instance, recycled PET (rPET) can retain allergenic residues from prior contents. 

Preventive Actions
To reduce risks associated with allergens in recycled materials, food packaging companies should take the following steps: 

1. Source Verification: Ensure suppliers of recycled materials follow thorough cleaning and certification processes. 

1. Traceability and Documentation: Maintain records of the origin and processing of recycled materials to identify potential allergen risks. 

1. Testing Protocols: Implement routine testing of recycled materials for allergen content before use in food-contact packaging. 

Eight Actionable Steps for Allergen Management in Food Packaging 

Step 1: Conduct a Comprehensive Allergen Hazard Analysis and Risk Assessment (HARA) 

• Identify Allergen Sources: Evaluate all materials, including adhesives and inks, for allergen content. Assess recycled materials for potential residues and review equipment for proper cleaning procedures. 

• Conduct a Risk Assessment: Determine the likelihood and severity of allergen cross-contamination from each source. 

• Implement Mitigation Strategies: Develop supplier controls, use dedicated equipment, and establish training programs to raise staff awareness. 

Step 2: Supplier Approval and Raw Material Assessment
Establish a robust supplier approval process focused on allergens. Ensure the specifications for all raw materials include: 

• Allergen Presence: Confirm whether raw materials contain allergens e.g wheat-derived starch in paper-board 

• Cross-Contamination Risk: Evaluate the potential for allergen cross-contact during transport and storage. 

Step 3: Keep Allergen Knowledge Current 

Maintain current knowledge of allergens relevant to your operations, including: 

• Regulatory Updates: Regularly review changes in allergen regulations and labelling requirements. 

• Employee Training: Conduct ongoing training sessions for all staff on allergen management best practices. 

Step 4: Implement Effective Allergen Segregation 

Physical segregation of allergenic materials is essential for minimizing risks. This can involve: 

• Dedicated Storage Areas: Designate specific areas for allergenic materials to prevent cross-contact with non-allergenic materials. 

• Colour-Coded Equipment: Utilize colour-coded tools and equipment to distinguish allergenic operations from non-allergenic ones. 

Step 5: Develop Comprehensive Allergen Handling Procedures
Create strict procedures for handling allergenic materials, including: 

• Dedicated Equipment: Ensure specific machinery and tools are designated for allergenic product lines and clearly marked. 

• Enhanced Cleaning Protocols: Implement rigorous cleaning schedules to remove allergen residues from equipment and work areas. 

• Document Protocols for allergens that may be handled in non-production areas of the site (e.g. in canteens or in new product development). 

  

• Develop a policy for food brought on-site by personnel Consider vending machines and catering facilities.  Your policy may ban certain allergens or restrict them to certain areas of the site. 

Step 6: Monitor Airborne Allergen Risks
Airborne allergens pose significant contamination risks, especially when working with fine powders. To mitigate this risk, consider: 

• Physical Barriers: Use protective equipment like shrouds during the handling of allergenic powders to minimise airborne exposure. 

• Airflow Management: Position ventilation systems strategically to prevent the spread of airborne allergens throughout the facility. 

Step 7: Establish Waste and Spillage Management Protocols 

Develop procedures for managing waste and spills involving allergenic materials. This includes: 

• Efficient Cleanup Processes: Ensure allergen spills are cleaned up promptly to prevent further contamination. 

• Clear Waste Disposal Guidelines: Train staff on proper disposal methods to avoid allergen cross-contact in the waste management process. 

Step 8: Regularly Review Allergen Management Practices 

Continuous improvement is vital for allergen management. Conduct regular reviews of your allergen management practices, including: 

• Annual Assessments: Reassess your Hazard Analysis and Risk Assessment (HARA) annually to ensure it reflects current operations and risks. 

• Adaptation to Changes: Revise your procedures as necessary to address any changes in raw materials, processes, or regulatory requirements. 

Conclusion 

Grasping the risks of allergen contamination from Food Contact Materials (FCM) is crucial for effective allergen management in your Food Safety Management System. By understanding these risks and their sources, you can take meaningful steps to protect consumers. Implementing the 8-Step Programme is a powerful way to enhance your strategy, and regular reviews will keep you aligned with the latest regulations and industry standards.
Sources 

1. BRCGS Packaging Issue 7 Interpretation Guide. 

1. Food Standards Agency (FSA) – Allergen Management Guidelines. 

1. U.S. Food & Drug Administration (FDA) – Food Allergens Information. 

1. International Food Safety Standards – Allergen Control Recommendations.