Allergens are a food safety hazard, just like bacteria. That is why a workplace's self-checking system (APPCC, the Spanish name for HACCP) must include their management. Regulation (EC) 852/2004 requires businesses to have procedures based on the HACCP principles, and Regulation (EU) 1169/2011 and Real Decreto 126/2015 require allergen information to be provided. A good plan brings it all together.
What is an allergen plan
It is a set of rules, sheets and records that say how to stop an allergen reaching a dish without warning. It is normally part of the prerequisite programmes and relies on the HACCP hazard analysis.
Usual steps
- Identify the allergens that come in and are used in the workplace.
- Know the ingredients of every dish and every product bought.
- Draw up recipe sheets and an allergen table for each dish, with periodic review.
- Control suppliers: ask for specification sheets, check for recipe changes and check the labels when each order arrives.
- Store in an orderly way: allergens covered, labelled and separated, or below foods without allergens.
- Plan production: dishes without the allergen first and those with it afterwards, or separate areas and utensils.
- Clean effectively between preparations and after using shared equipment.
- Inform the customer in writing, and orally when the conditions are met.
- Train all staff (kitchen, floor, shop and cleaning), including those who arrive mid-season.
- Record and verify: note training, sheet reviews, incidents and corrective actions.
When it must be reviewed
The plan must be updated when:
- an ingredient or a supplier changes;
- a new dish or a seasonal recipe is added;
- equipment is bought or the kitchen is altered;
- there is a complaint, an incident or a reaction;
- the regulations or the autonomous community's guidance change.
Responsibilities
- Management ensures that the plan exists, that sheets are up to date and that training takes place.
- The kitchen knows the ingredients, applies the measures to avoid cross-contact and reports changes.
- Floor and shop staff give information based on the sheet and pass allergies on to the kitchen.
- Purchasing and goods-in check labels and product changes.
- All staff can and must speak up if they see a risk.
What to record
- Allergen sheets and their review date.
- Supplier specification sheets.
- Staff training.
- Cleaning and checks the business has defined.
- Incidents, complaints and corrective actions.
What your employer still has to do
This course explains the concepts. It does not replace the sheets and procedures of your own workplace. Your employer must give you specific instructions about your kitchen, your dishes, your suppliers and your utensils, and check in practice that you know how to apply them. Some autonomous communities (Spain's regions) publish their own guidance, and your business must follow whichever applies to it.
Key points
- Allergens are a hazard that HACCP must manage.
- An allergen plan uses recipe sheets, supplier control, storage, cleaning, information and training.
- It must be reviewed whenever an ingredient, a supplier or a recipe changes.
- Your employer has to give you specific instructions for your job.