Hold the nuts, please

As an allergen, nuts might not be as prevalent as wheat flour and
gluten, but the consequences of ignoring them can be much more
dangerous – even fatal.
With schools removing food products containing nuts from their menus,
bakeries and other food manufacturers are under pressure to comply with
strict safety, sanitation and ingredient traceability rules, such as
those set out in the Hazard Analysis Critical Control Path (HACCP)
program.

As an allergen, nuts might not be as prevalent as wheat flour and gluten, but the consequences of ignoring them can be much more dangerous – even fatal.
With schools removing food products containing nuts from their menus, bakeries and other food manufacturers are under pressure to comply with strict safety, sanitation and ingredient traceability rules, such as those set out in the Hazard Analysis Critical Control Path (HACCP) program.

Touché Bakery, a London, Ont.-based producer of biscotti, meringues, cookies and dough, has invested several years and untold sums of money to become Canada’s first HACCP Advantage Plus-certified commercial bakery, and president and CEO Allan Swartz couldn’t be happier with the results. Last November, he and his wife, Peggy, who handles the bakery’s sales and marketing, unfurled their HACCP banner and hung it from the rafters of their sparkling-clean, 16,000-square-foot facility in southeast London.

“That’s the most expensive banner in the world – you don’t want to know how much it cost per square foot,” Swartz joked when we spoke in late January. “So I understand why people don’t want to go with it. It really is a costly, arduous process, and if you’re not committed, it doesn’t work.”

There are different levels to HACCP certification in Canada, Swartz explained, with Advantage Plus being the highest and most difficult to obtain (the others are Advantage GMP, for good manufacturing processes, and Advantage HACCP Certified), not only because of the financial investment in upgrades to the bakery’s equipment and facilities, but also because of dramatic changes to record-keeping practices, ingredient traceability, supplier integrity, sanitation, security and staff training.

“My rationale was if we do it, we do it right,” Swartz says. “It took us a little over a year, and that’s fast-tracked. A lot of companies do it over a longer period of time because of the physical changes to their plant.

“For example, we built a special wash-up room to clean our equipment; we segregated shipping/receiving from production; we extended the walls all the way up to the ceiling, and had to remove all the glass and hard plastic from the facility. All the light bulbs had to have shatter shields. Staff had to have a separate set of clothing and shoes to wear in the plant. Visitors are questioned when they walk in whether they’ve recently eaten peanuts or tree nuts,” … and so on.

Swartz’s rundown of what Touché Bakery went through to become one of only a handful of HACCP Advantage Plus companies in the entire country was truly dizzying, but what seems to have been most difficult was the paperwork.
“It’s not like in school where you graduate and get your diploma and it’s over. It’s continuous and we always have to improve our paperwork,” he says.

“We do a lot more documentation on goods coming in, recording lot numbers throughout the process, lot codes from raw materials and how they relate to our lot codes. So when we make batches of dough every batch has a lot code and within that is the lot code of all the ingredients. So it’s an enormous amount of paperwork. And the hardest part was finding staff to do the paperwork. At your typical bakery, if you’re combining flour, sugar, water and all the other ingredients, no one’s bothering to record all the lot numbers.”

Worst – or best – of all, the HACCP paperwork can’t be solely electronic.
“Everything has to be able to be tracked and signed off, so we have binders and binders and binders full of documentation,” Swartz says. “But it’s a way of life for us now, and if we don’t follow it someone with an allergy will suffer. A lot of consumers don’t understand HACCP but the retailers understand what it means and they know our plant has high standards.”

Before buying ingredients from a new supplier, Touché Bakery, which is also a certified-kosher facility, requires an allergen assessment in which the supplier must specify whether allergens such as peanuts, tree nuts, eggs, milk, soybeans, fish, shellfish, etc., are A) present in the product; B) present in other products manufactured on the same line; or C) present in the same manufacturing plant. If B or C are true of any of the allergens listed on the assessment, the supplier must specify whether they have effective procedures to avoid cross-contamination of the ingredient intended for sale to Touché Bakery.

“When we get frozen goods in, we check the temperature in the truck to make sure it’s correct. It’s important because some things, if they thaw, you’re going to have issues,” Swartz says. “We also check the condition of the vehicle – if goods come in on a truck and the floorboards are shot, we reject the shipment. If there’s a chance of contamination, if bags or boxes are broken or something like that, we reject it. Our supplier of cartons had to provide us documentation about the inks they used. It seems excessive, but the consumer is the beneficiary of all this, ultimately.”

Also, if you’re thinking of visiting Touché Bakery, lay off the peanut butter – it’s fallen out of favour with most people, anyway, due to the salmonella outbreak.

“We had to refuse entry to a tradesman who’d just eaten a peanut butter sandwich. He couldn’t do the work he’d been asked to do because he was contaminated,” Swartz says. “Yeah, I guess you could say I’m kind of anal, but you have to be. And if I don’t care, staff won’t care.”

Touché Bakery’s products might be safe, but are they any good? Swartz answered that question with a variety of samples of the company’s biscotti, cookies and meringues. The verdict? Delicious.

That’s because Swartz, who was a partner in the gluten-free food company Gluteno before buying Touche in 2004 and moving it from Cornwall to London, believes qualities such as taste and texture shouldn’t take a backseat to safety. And with a growing roster of retailers, including Sobeys and London Drugs, as well as direct sales to schools for fundraisers, consumers are discovering the results of that belief for themselves.

“Our first objective is to make a great product,” he says. “Being kosher and nut-free is a bonus. The reason we are getting into more places is the quality of the product, not because we’re nut-free. When I was in the gluten-free business in the early ’90s, gluten-free was like eating wet cardboard. People bought the product because they had no other choice. Regular consumers wouldn’t buy it because it tasted terrible. People buy our product because of the taste, texture and quality, and hey, if you have a nut allergy, you’ve still got a great product.”

Swartz says Touché Bakery is ahead of the food-safety curve with its
groundbreaking HACCP Advantage Plus certification, but that’s mainly due to the state of the economy.

“It’ll be three or four years before someone else goes through with this. If I had to initiate a HACCP program now, I definitely would have delayed it because of the economy,” he says. Still, these allergies aren’t going to go away, if anything they’ll get worse. But with HACCP, you do it, not because of the allergen issue, but because it raises your standards and customers recognize that you take a lot of care in your manufacturing process.”

Despite Touché’s arduous road to HACCP certification, Swartz says the process has given the bakery an identity and culture it didn’t have before.

“We’ve had to be different. We’re not Proctor & Gamble, we’re not Nabisco – we have only 22 employees (one of whom is a full-time HACCP quality-control supervisor) so we had to find a niche. And a big part of that is quality. That’s where HACCP came in and gave us an advantage.

“As a result, we get e-mails that are really moving, like ones from parents saying their homes are so much safer for a child who has a nut allergy, and that they don’t have to worry as much anymore.

“That’s nice to hear.” / BJ

On the Web:
www.touchebakery.com
www.omafra.gov.on.ca/english/food/
inspection/haccp/index.html
www.inspection.gc.ca/english/fssa/polstrat/haccp/haccpe.shtml