An allergen control plan is how a kitchen keeps each product's allergens where they belong and off everything else, and gets the label right. FDA's preventive controls rule describes food allergen controls as the procedures for protecting food from allergen cross-contact, in storage, handling and use, and for labeling the finished food so it isn't missing an allergen. A small maker's plan has seven parts: an allergen inventory, receiving, storage, scheduling, changeover cleaning, packing and label checks, and training, each with who does it, when, and where it's recorded. In the example below, a cookie maker writes its plan after a recall, when peanut butter cookies ended up in bags labeled brown butter pecan. Below is each part, the plan, the log, and a free workbook.
The short version
- Start with an inventory: every ingredient and the major allergens it carries.
- Check each delivery's label against the approved list; a changed ingredient statement stops at the door.
- Store allergen ingredients sealed, labeled, and below everything else.
- Schedule from fewest allergens to most, and never two allergen products on the bench at once.
- Clean fully after allergen runs, and have a second person check.
- Keep one product's packaging at the packing table, and check the first bag of each lot against the recipe.
- Train everyone on the plan on day one, and again every year.
- TaroStack keeps changeover and label checks on each batch record, with its lots. More below.
The rules behind it
Food allergen controls are one of the preventive controls a food safety plan names: procedures to protect food from allergen cross-contact, during storage, handling and use, and to label the finished food so it's not misbranded for a missing allergen (21 CFR 117.135(c)(2)). The label itself follows the allergen labeling law (21 U.S.C. 343(w)). How to declare allergens on a label is in allergen matrix template. This is general information, not legal advice.
The seven parts
| Part | What it covers |
|---|---|
| Allergen inventory | Every ingredient and the major allergens in it, supplier by supplier |
| Receiving | Each delivery checked against the approved ingredient list and spec |
| Storage | Allergen ingredients sealed, labeled and stored where they can't spill onto others |
| Scheduling | The order of the day's runs, fewest allergens first |
| Changeover cleaning | What's cleaned after an allergen run, and who checks it |
| Packing and labels | One product's packaging at a time; a label check each lot |
| Training | Who's trained on the plan, when, and the record |
An example: a cookie maker's plan
Granite Peak Cookie Co., a made-up cookie maker in Sandy, Utah, I use in these examples, recalled a lot in October when peanut butter cookies were packed in bags labeled brown butter pecan, and rewrote its allergen controls the same week:
| Control | What it does | Who | When | Record |
|---|---|---|---|---|
| Receiving | Each delivery's label checked against the approved list; a changed ingredient statement goes to the owner | Receiver | Each delivery | Receiving record |
| Storage | Peanut butter and pecans in sealed, labeled bins on the bottom shelf | Everyone | Always | Weekly walk-through |
| Scheduling | Plain and chocolate chip first, pecan next, peanut butter last; one allergen product on the bench at a time | Production lead | Daily | Schedule |
| Changeover | Full clean of bench, mixer, scoops and trays after pecan and peanut butter; checked by a second person | Baker, checker | Each changeover | Batch record |
| Packing and labels | Only one product's bags at the packing table; first bag of each lot checked | Packer | Each lot | Packing record |
| Training | The plan on every new hire's first day, and yearly | Owner | On hiring, yearly | Training log |
The recall came from the packing table: two products' bags were out at once. That's why "one product's bags at a time" and the first-bag check are the controls Granite Peak added first. Its inventory shows six of the nine major allergens in the kitchen: milk, egg, wheat, soy, tree nuts and peanuts. What the recall itself involved is in how to write a recall letter, and the steps after an allergen slip in undeclared allergen recall.
The log
| Date | From | To | Cleaned by | Checked by | First bag matches recipe | Lot |
|---|---|---|---|---|---|---|
| Oct 19 | Brown butter pecan | Peanut butter | MS | TK | Yes | GPC-1019-B |
| Oct 19 | Peanut butter | End of day, full clean | MS | TK | ||
| Oct 20 | Chocolate chip | Brown butter pecan | TK | MS | Yes | GPC-1020-B |
Get the workbook
Download the allergen control plan template. Three sheets: the allergen inventory, each ingredient with an X under each major allergen it carries, where the allergens in the kitchen fill in; the controls, each with what you do, who, when and the record; and a changeover and label log. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A plan on paper says what should happen. Whether it did is in the log, and a log on a clipboard can't say which batches were packed on a day the first-bag check was skipped, or which cafés got them.
How TaroStack does it
TaroStack keeps changeover and label checks on each batch record, with its lots.
Checks on the batch record. Fields of your own on the batch record, tick boxes and initials, hold the changeover clean, the second person's check and the first-bag label check, for every batch, and printable batch-record forms carry them for the kitchen.
Receiving with its check. Fields of your own on each receipt record that the delivery's ingredient statement matched the approved list, so a supplier's change is caught at the door.
Lots to cafés. Each batch records the lots it consumed, and each order records the lots each customer got, so if a check was missed, one recall report shows who got that batch, and a hold keeps the rest from shipping.
| The job | Clipboard | In TaroStack |
|---|---|---|
| Changeover and second check | A log sheet | Tick boxes and initials on the batch record |
| First-bag label check | Remembered | A field on the batch record |
| A supplier's changed ingredients | Noticed, maybe | A field on the receipt |
| Who got a batch | Search the invoices | One recall report |
Batches, receipts and batch records with fields of your own, holds and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.