Operations enrolled in certification options B, C, and D are required to complete the allergen section (including Form S). The simplest way for operations to complete the requirements is to use Form S. They will begin by looking at all of the potential allergens listed in the left hand column in the Form and assess whether or not they are present in their operation. If the allergen is present, the person responsible should answer YES in the appropriate spot in Columns I – V (where applicable). If the allergen is not present, they should answer NO. It may be possible for an operation to end up with a NO answer for every box.
If an operation does answer YES in one of the boxes, they must keep product free from cross-contamination (if possible). This would mean keeping the product and potential allergen separate (not on top of, underneath, or touching). Any control measures being used should be recorded in the last row of Form S. The program does not require additional corrective measures at this time (e.g., stopping a certain practice etc. if it presents an allergen risk).
By completing Form S, the operation has done an assessment of potential allergens and shown their due diligence. Once Form S has been completed, the person responsible should then go to Section 23.6 (Allergens) and check off the boxes in that section. Auditors will be looking for a completed Form S and Section 23.6 when scoring this requirement in the Audit Checklist.
Some examples of potential allergen situations in operations could be:
- storing milk or dairy products in the same cooler as fruits and vegetables
- egg producer who is also a fruit and vegetable producer
- using peanut butter or cheese inside “tin cat” traps for rodent control
- soybeans grown in fields adjacent to fruit and vegetable production
- mustard/mustard seed grown in production sites in rotational years
It should be noted that these practices may still take place, but that they need to be noted on Form S, and where possible, measures should be taken to reduce cross contamination.