Allergen Control Verification

Aligned with SQF Code Edition 9 – System Element 2.7.3

Requirement Overview

SQF Code Edition 9, System Element 2.7.3, states:

“Allergen control measures shall be verified through testing or validation where necessary to demonstrate effectiveness.”

Verifying allergen control measures ensures that cleaning, separation, and labeling procedures are working as intended—and helps reduce the risk of cross-contact and product recalls.

Disclaimer: Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). This article is for educational and compliance support purposes only. For official guidance, visit www.sqfi.com.

Key Compliance Objectives

  • Develop a risk-based verification plan for allergens

    Scientifically validate cleaning and sanitation procedures

    Establish documented testing protocols

    Maintain a corrective action system for any failures

Step-by-Step Compliance Implementation

1. Develop an Allergen Verification Strategy

  • Testing Frequency by Risk Level:

Risk Level Verification Method Recommended Frequency
High (e.g., peanut lines) ELISA + ATP testing After every cleaning cycle
Medium (shared lines) Visual + ATP Weekly
Low (dedicated equipment) Visual inspection only Monthly

  • Evidence to Maintain:

    • Approved verification plan and decision matrix

      Allergen risk assessments by product, process, and line

      Method justifications and testing protocols

2. Validate Cleaning Procedures Scientifically

  • Validation Protocol Should Include:

    • Worst-Case Scenario Testing – After the longest run or most difficult allergen

      Full Equipment Disassembly – Include hard-to-clean areas like gaskets or augers

      Scientific Testing Method – ELISA, PCR, or validated lateral flow kits

    Evidence to Maintain:

    • Validation reports with photos of teardown

      Swab locations and test results

      Justifications for selected test methods

3. Implement Routine Allergen Testing

  • Testing Program Components:

    • Swab locations: 10–20 sites per line (post-clean, pre-production)

      Use validated test kits appropriate to your product matrix

      Acceptance criteria: e.g., <5 ppm gluten or “not detected” for milk

    Evidence to Maintain:

    • Swab logs with dates, locations, and technician name

      Calibration and expiration records for test kits

      Trend reports showing pass/fail rates

4. Monitor, Analyze & Improve

  • Data Management Best Practices:

    • Conduct trend analysis to spot recurring hot spots

      Maintain logs of corrective actions for failed results

      Perform annual program reviews and revalidations as needed

    Evidence to Maintain:

    • Monthly analysis reports

      Root cause investigation documentation

      Training updates or procedural changes

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Solution
No allergen cleaning validation Conduct validation with ELISA or third-party lab
Swabs taken from wrong locations Re-map swab zones and train testing staff
Unvalidated test kits used Use only kits validated for your food matrix
No trend tracking or reviews Implement monthly report analysis and escalation

Auditor Verification Checklist

Expect auditors to:

  • Review allergen testing protocols and risk assessment

    Verify swab logs and test results by line/product

    Examine equipment teardown procedures used in validation

    Confirm that corrective actions were implemented and verified

Implementation Roadmap

Build Your Program

  • Develop a testing frequency matrix by risk level

    Map out swab sites for each line

Train and Validate

  • Validate worst-case cleaning scenarios

    Certify QA staff in allergen swab testing procedures

Operate and Monitor

  • Conduct routine tests (swabs, ELISA, ATP)

    Track results and log all corrective actions

Improve Continuously

  • Perform quarterly reviews of testing data

    Revalidate cleaning procedures annually or after changes

Why This Matters?

Effective allergen verification:

  • Confirms that your allergen control program works

    Reduces the risk of undeclared allergen recalls

    Demonstrates due diligence in customer and regulatory audits

    Protects brand reputation and consumer safety

Need Help Building or Validating Your Allergen Program?

Food Safety Systems provides:

  • Allergen verification plan templates

    Cleaning validation protocols and test logs

    Equipment-specific swab site mapping templates

    Audit prep checklists and corrective action forms