BRCGS unannounced audit allergens: Maintaining Continuous Allergen Control Readiness

BRCGS unannounced audit allergens requirements have changed how food manufacturers must operate. Food safety businesses now face at least one unannounced audit every three years. Audits may occur four months before the scheduled due date^[25]. There’s no advance notice to update records, refresh training, or verify cleaning protocols. BRCGS auditors report deeper scrutiny of allergen management, supplier approval processes and contingency planning in 2024 and 2025^[1]. We’ll walk you through a continuous allergen control readiness culture that keeps your site compliant every day.

What Makes Unannounced BRCGS Audits Different for Allergen Control?

Why BRCGS Introduced Mandatory Unannounced Audits

The Global Food Safety Initiative (GFSI) published Benchmark Version 2020 with a most important move in certification requirements. GFSI mandated that certificated sites must undergo at least one unannounced audit every three years because of concerns about audit predictability and the desire for more authentic assessments of operating standards^[26]. BRCGS responded by introducing mandatory unannounced audits as part of Food Safety Issue 8, Packaging Materials Issue 6 (effective February 1, 2021), and Storage & Distribution Issue 4 (effective May 1, 2021)^[25].

The main goal behind this change focuses on building an audit-ready food safety culture rather than catching sites unprepared^[26]. GFSI and BRCGS recognised that announced audits created a cycle where facilities would intensify compliance activities in the weeks before an audit and then revert to less rigorous practises afterward. Unannounced audits provide certification bodies and customers with independent verification that systems remain in good order throughout the certification period, not just during scheduled assessment windows.

Data from 2014 unannounced audit programmes revealed that sites on the unannounced audit programme were 9% more likely to achieve a grade A when renewing certification compared to those opting for announced audits^[27]. This improvement stems from the better preparation and more developed food safety culture that sites adopt when they know an auditor could arrive at any time. Around 85% of sites reported that the unannounced approach did not alter their fundamental approach to food safety^[27]. This suggests the format change reinforces existing good practises rather than requiring new systems.

How Unannounced Audits Change Allergen Management Expectations

BRCGS treats allergen management as a Fundamental requirement under Issue 9^[28]. A Fundamental nonconformance results in an automatic critical finding, which means a failed audit whatever the performance in other sections. Because of this classification, unannounced audits place much higher pressure on allergen control systems. There’s no advance warning to verify documentation, refresh validation records, or ensure all staff are briefed on current procedures.

Clause 5.3 requires a documented allergen policy, site-specific allergen risk assessment, and controls for segregation and cross-contact prevention^[28]. BRCGS auditors conduct allergen-specific verification during unannounced visits. They request immediate access to risk assessments, cleaning validation records, production scheduling controls, and evidence of label reviews following formulation or supplier changes. Any single missing element can generate a major finding^[28].

The move from announced to unannounced audits changes the compliance model entirely. Auditors observe GMPs in action and expect real-time demonstration that written procedures match floor practises^[11]. This means changeover protocols must be executed correctly every single day for allergen control, not just perfected before predicted audits. Personnel hygiene, traffic flows, sanitation tools, and housekeeping must reflect documented standards consistently. Auditors look for consistency between what’s written in SOPs and what happens on production lines.

The 4-Month Audit Window and What It Means for Your Site

The unannounced audit can occur at any time during the four months prior to your audit due date, including the 28 days before the due date^[26]. Certification bodies manage this process by ensuring audit dates remain unannounced. They use the entire audit window rather than scheduling all unannounced audits within the final 28 days and avoid using the same audit dates on consecutive years^[26].

Sites receive the chance to nominate days when audits cannot take place, but restrictions apply. You can block a maximum of 10 days (or 5 days for sites audited every six months)^[29]. Legitimate reasons include planned customer visits with technical staff and managers, but the absence of a specific employee doesn’t qualify as grounds for a non-audit day^[29]. You must communicate dates and reasons to the certification body at least four weeks in advance.

If the auditor arrives for an audit and is denied access, the site’s certification will be suspended^[26]. Sites must accommodate the auditor and allow the audit to commence upon arrival. This requirement means your allergen control systems, documentation, and staff readiness must be managed to keep at audit-acceptable standards every single operational day within the four-month window. Around 50% of sites surveyed felt the unannounced audit provided a better reflexion of their actual operation^[27]. This reinforces that the format captures everyday performance rather than best-case scenarios.

Understanding BRCGS Allergen Requirements for Unannounced Assessments

Allergen management pervades every aspect of the BRCGS Standard^[30]. Even clauses that don’t mention allergens can trigger allergen-related failures during production. Auditors get into how prerequisite programmes intersect with allergen control and traceability systems to determine whether sites maintain the level of control required for unannounced assessments. Physical segregation measures play a key role here.

Core Allergen Control Clauses Auditors Prioritise

BRCGS Issue 9 requires documented validation when a prerequisite programme manages a specific hazard^[31]. Cleaning regimes designed to prevent allergen cross-contamination must have documented validation that the prerequisite controls the identified hazard^[31]. This difference separates general environmental controls from operational prerequisites (oPRPs) that address specific food safety risks.

Validation evidence has worst-case production and cleaning trials, where all equipment, processes and allergens must be thought about^[31]. Auditors expect targeted test locations such as food contact surfaces and difficult-to-clean areas^[31]. Validation tests should use accredited methods that are quantifiable wherever possible^[31]. Rapid tests, ATP and lateral flow devices serve verification activities but aren’t suitable to validate^[31].

Sites must collect validation data from several production runs to ensure the data is representative and complete^[31]. Positive testing of the test method confirms it will detect the allergen if present in a real sample. This verifies that the product matrix won’t interfere with the test^[31]. FSMA’s Preventive Controls rule requires written allergen controls for storage, processing, cleaning and labelling. ISO 22000, FSSC 22000 and GFSI schemes treat allergen management as a prerequisite programme integrated with HACCP and verification^[8].

Documentation Standards for Allergen Management

An allergen management plan serves as a documented system that identifies, controls, educates and communicates the risk and presence of allergens on site^[32]. This plan moves from raw materials through to finished products. It has a risk assessment of allergen cross-contact, plus implemented controls to minimise or eliminate contamination risk^[32].

The plan defines policies and procedures to manage allergens within the site and must have a detailed Hazard Analysis and Risk Assessment (HARA)^[33]. Auditors verify that specific cleaning procedures for areas or equipment potentially cross-contaminated with allergens are validated and verified. Documented check records support these procedures^[33]. Any products containing allergens should be stored and handled to minimise contamination potential for materials that don’t contain them^[33].

The allergen management plan requires review when there’s a change to raw materials or suppliers. Modifications in the manufacturing process, introduction of new machinery, or changes to cleaning practises and procedures also trigger review^[33]. Sites need a mechanism to remain current with good practise and legislative requirements as new research emerges^[32].

Traceability and Segregation Expectations

Traceability under Clause 3.9 requires food businesses to demonstrate they can track materials both forward to customers and backward to suppliers. Speed and accuracy matter here^[34]. Full batch or lot level traceability must cover raw materials, packaging, rework and finished goods^[34]. Sites must perform a complete traceability exercise within hours, not days^[34].

Physical separation warrants thought where risk exists: segregated rooms or lines, dedicated tools, marked zones, and directional traffic flows^[8]. Clear allergen taxonomy in master data attaches to materials, recipes, equipment and storage locations^[8]. Risk-aware sequencing runs non-allergen products before allergen products. Controlled rework prevents allergen rework from contaminating non-allergenic products^[8].

Label governance requires approval workflow and print interlocks so declared allergens cannot drift from reality^[8]. Traceability non-conformances emerge as some of the most common issues during BRCGS audits. These include incomplete link information between raw materials, work-in-progress and finished products. Inconsistent rework usage records and traceability exercises exceeding four-hour expectations also appear frequently^[34].

How Can Sites Stay Audit-Ready Year-Round?

Moving from reactive compliance to continuous readiness means you need to rethink how allergen control blends into daily operations. Sites that treat audit preparation as an isolated event struggle when auditors arrive unannounced. Year-round readiness demands cultural transformation backed by systematic daily practises and technology that removes manual gaps.

Building a Continuous Readiness Culture

Food safety culture is the bedrock of BRCGS audit readiness and shows auditors that allergen control isn’t a compliance exercise but an ingrained operational principle^[35]. Leadership must set the overall direction and enable employees to take ownership of allergen control through complete training, clear communication of procedures and acknowledgement of contributions^[35]. This shared responsibility turns every person from production to warehousing into an active participant.

Continuous improvement drives long-term success rather than viewing allergen control as a static achievement^[35]. Regular monitoring identifies potential hazards and prompts corrective actions right away rather than waiting for scheduled reviews^[35]. Organisations committed to high standards adopt a proactive, always-on approach that blends food safety into daily operations^[36]. Leadership buy-in proves essential because executives and managers must prioritise allergen control and support compliance initiatives^[36]. Documented management commitment serves as the foundation for strong food safety culture and shows dedication to continuous improvement^[36].

Mock audits serve as genuine rehearsals rather than superficial exercises^[1]. Cross-functional teams should mirror the depth and pace of actual BRCGS audits and include documentation checks, hygiene inspections, traceability tests and allergen control reviews^[1]. Floor walks across every zone and shift verify that documented practise matches actual floor practise^[2]. Pick five random procedures, stop operators and ask them to walk through each step while noting discrepancies^[2]. Random operator interviews covering allergens, CCPs, foreign body procedures, personal hygiene rules and food safety culture commitment reveal training gaps before auditors do^[2].

Daily Allergen Verification Practises

Cleaning, storage and cross-contamination controls must blend into HACCP plans with daily monitoring^[37]. Automated systems flag missed actions so nothing slips through unnoticed^[37]. Your allergen management system requires full review at minimum once a year. This covers whether supplier allergen declarations remain current and match products you use now, whether recipe allergen data stays accurate and updated, whether cross-contamination controls suit the current production environment, whether labelling remains correct for the current product range and whether training records are complete and current^[3].

Staff training and competency verification warrants particular attention. Every member involved in food preparation, production, labelling or customer service just needs to understand their role in allergen management, what they’re responsible for, what actions to take when noticing errors or changes affecting allergen information and how to respond to customer allergen queries^[3]. Training must be documented and refreshed when processes change^[3]. Auditors interview operators, line workers and sanitation staff to confirm understanding of food safety responsibilities during unannounced visits^[38].

Live Record Keeping and Digital Systems

Accurate record-keeping proves due diligence when complaints, inspections or legal queries arise^[37]. Digital logs should capture ingredient sourcing and supplier allergen statements, cleaning and cross-contamination controls, staff training and declarations, plus allergen checks and corrective actions^[37]. Cloud-based platforms store everything securely with automatic time-stamping and keep records inspection-ready^[37]. Sites need at least 90 days of clean, complete records covering HACCP checks, CCP monitoring, sanitation verification, calibration, pest trend logs, training sign-offs and corrective actions^[11].

Purpose-built allergen management software provides ingredient-level tracking with automatic propagation to recipes and automatic label generation, audit trails and version history^[3]. Structured, timestamped and complete records help environmental health officers verify that allergen information remains current and accurate^[3]. Live ingredient tracking systems enable detection of potential allergens right away as ingredients move through the supply chain and allow quick responses to contamination risks^[39]. Tools supporting daily allergen control verification, such as ATP swab testing and cleaning verification systems, strengthen continuous audit readiness without requiring pre-audit scrambling.

Centralised documentation means anyone can locate specific clause-related records within two minutes^[13]. Version control maintains SOP currency while corrective action tracking provides closure evidence^[2]. Digital platforms unite audit documentation, supplier approvals and training records and give compliance visibility across multiple locations^[36].

Essential Allergen Control Systems for Unannounced Audits

Four operational systems are the technical foundations of allergen control readiness when BRCGS auditors arrive unannounced. Sites cannot rely on advance preparation to polish these systems. They must function at audit-acceptable standards every production day within the four-month window.

Confirmed Cleaning Procedures and Changeover Protocols

Cleaning validation proves that procedures remove allergens from shared equipment and reduce cross-contact risk to acceptable levels^[6]. This quantitative assessment is different from verification or monitoring. It provides scientific evidence that cleaning works repeatedly^[6]. BRCGS Clause 5.3.8 mandates that cleaning methods must be confirmed to ensure they work, with routine verification of procedure performance^[5].

Planning identifies worst-case scenarios by selecting high-risk equipment and target allergens that demonstrate removal of residue^[6]. Watching a clean take place helps identify difficult-to-clean areas where product accumulates^[6]. Sites with multiple similar lines using the same cleaning process need not confirm every line for every allergen^[6]. Quantitative ELISA methods serve as the preferred testing approach because they detect protein and make results clinically relevant^[6].

Positive control testing proves the chosen target allergen and test method suit the sample collected^[6]. This step confirms the ELISA kit detects the allergen in the actual food matrix on production lines^[7]. Several production runs must provide samples to ensure results are representative^[6]. Once confirmation shows cleaning works, sites shouldn’t repeat the process unless manufacturing processes change, cleaning methods alter, or ingredient profiles move^[6].

Documentation must record all decisions, results, outcomes and training records^[6]. Staff compliance and understanding of cleaning procedures remain essential for managing facilities with non-dedicated equipment^[6]. Product purge methods, where the first minutes of production after changeover are discarded, require confirmation to ensure the discarded volume protects subsequent production^[7].

Staff Training and Competency Verification

Personnel involved in handling, preparing, serving or managing food require training on allergen identification, cross-contact mechanisms and prevention procedures^[4]. Training extends beyond production staff to procurement and cleaning teams to ensure allergen controls span the whole operation^[4]. On-the-job training allows employees to learn allergen controls within their work environment and focus on real tasks while requiring consistent supervision^[4].

Competency checks and observations verify that employees understand allergen risks and apply procedures correctly^[4]. Observations during daily tasks identify knowledge gaps or unsafe practises, and regular assessments confirm training works^[4]. Corrective actions and retraining address issues found during inspections or incidents. They prevent repeat errors and deepen long-term allergen control^[4]. Retraining reinforces proper procedures and updates employees on menu, ingredient or regulation changes^[4].

Allergen Risk Assessment and Control Point Monitoring

Allergens constitute a chemical hazard requiring assessment at each ingredient and process step where allergens are handled^[14]. Sites operating under preventive controls must implement allergen preventive controls where allergens are present^[14]. Each allergen monitoring form in operations should be designated as an allergen preventive control on flow charts, in hazard analysis and within preventive control plans that specify responsible persons, frequency, records and corrective actions^[14].

Label inspections and schedule building represent simple allergen preventive controls, with additional controls added for programmes such as special line changeover or allergen-specific cleaning techniques^[14]. Food safety programme reviews, including allergen controls, must occur whenever plans change and at least once a year^[14].

Visual Inspection and Detection Methods

Visual inspection alone cannot verify allergen removal^[7]. Sites used a ‘visually clean standard’ with allergen checklists but lacked data to verify whether this protected allergic consumers before allergen test methods existed^[7]. Quantitative ELISA methods remain the preferred approach because they’re simple and sensitive enough to ensure products with no detectable allergen residue are safe^[7].

Following allergen confirmation, qualitative ELISA formats such as lateral flow strips may be used as cost-effective ongoing monitoring methods^[7]. Results have supported historical visually clean standards and suggest visual inspection remains adequate for ongoing monitoring after confirmation shows the process works^[7]. Tools like DrCleanish support daily allergen control verification as part of continuous audit readiness and enable routine checks without requiring pre-audit preparation.

Neither traditional ATP tests nor advanced A3 systems detect allergens, though A3 systems detecting all organic residue forms (ATP + AMP + ADP) could support ongoing cleaning verification^[5]. Sites must plan responses for positive test results before conducting any testing. This includes clear communication protocols with senior management for holding or destroying product pending results^[7].

What Auditors Look for During Unannounced Allergen Inspections

Auditors arriving for unannounced BRCGS inspections focus on observable evidence that allergen controls function as written procedures describe. Floor walks reveal whether physical controls, documentation practises, and staff competency line up with your allergen management plan. These inspections get into four critical areas where non-conformances emerge most often.

Physical Segregation and Storage Controls

Auditors scrutinise storage arrangements first. They verify that allergen-containing ingredients are identified on packages upon receipt, using colour coding, tags, or distinctive marks to show allergen content during storage and production floor use^[15]. Segregated storage areas provide physical separation for allergen and non-allergen ingredients. Dedicated rooms or shelving work best^[15]. Where dedicated areas aren’t available, allergen-containing materials must be stored at floor level or lower shelves to prevent cross-contact if packaging gets damaged and leakage occurs^[15][16].

Auditors check that ingredient packaging remains sealed and that all packs are resealed after use^[16]. Storage procedures must specify how different ingredients should be handled. Standard Operating Procedures and work instructions for spillage management should be available^[16]. Master data should attach allergen taxonomy to materials, recipes, equipment and storage locations^[8]. Digital zoning prevents allergen lots entering non-allergen bins, whilst manufacturing execution systems block issuing an allergen to a non-allergen batch without verified changeover evidence^[8].

Label Control and Rework Management

Label reconciliation records confirm correct label application for every production run^[9]. Each run must have a label reconciliation record covering pre-start label verification and end-of-run count of issued, used and destroyed labels^[9]. Any discrepancy requires a completed investigation and product disposition decision on file^[9]. Control procedures ensure proper labelling of raw materials, semi-finished goods and products, including rework and waste^[17].

Your allergen management plan must document rework procedures that account for allergen status^[18]. Auditors verify that rework containing allergens is reincorporated only into products with matching allergen profiles^[15][19]. Colour-coded tags should identify and record when reworked products with allergenic ingredients are produced, where they’re stored, which products they’re reworked into, and how much is used^[19].

Cross-Contact Prevention Measures

Production scheduling separates allergen-containing products from non-allergen products by time. Foods containing fewest allergens are produced first and most allergens produced last^[15][18]. Auditors observe whether dedicated equipment, protective clothing or colour-coded tools exist for allergen preparation^[18]. Traffic patterns of raw materials, packaging supplies and employees must be limited during manufacture of allergen-containing products to prevent cross-contact^[19].

Employee Knowledge and GMP Compliance

All production staff must have role-appropriate food hygiene training with assessed competency on record. This includes seasonal, agency and temporary workers^[9]. Allergen awareness training completion and assessment for all food handlers warrants particular attention given regulatory and consumer safety implications^[9]. Training records must show both completion and competency assessment results for every food handler on the production rota^[9]. Auditors interview operators to confirm understanding of site allergens, cross-contact risk and control, plus escalation procedures for suspected allergen contamination events^[9].

Common Allergen Control Failures in Unannounced Audits

Most BRCGS allergen non-conformances stem from gaps between documented procedures and actual floor practise. Unannounced audits expose these disconnects right away because sites lack time to resolve discrepancies before assessment begins. Four failure patterns account for the majority of allergen-related findings during unannounced visits.

Incomplete Cleaning Records and Verification Gaps

Cleaning validation documentation lacks the decisions made before starting the validation process in many cases. Sites must document reasons for targeting specific allergens, decisions on where to take swabs, and the rationale behind equipment selection. This proves the business has done everything reasonably practicable to ensure cleaning effectiveness^[6]. Documented decision records allow others to understand what has been done when the person who conducted cleaning validation leaves or becomes unavailable^[6].

Hidden equipment harborage creates repeatable root causes for allergen failures. Gaskets, joints, dead-legs and difficult-to-reach locations harbour allergenic residues even when surfaces appear clean^[20]. Rushed changeovers compound this problem as personnel skip dismantling steps required to access all product-contact surfaces. Dust redistribution from high-pressure hoses or air blowing distributes powder or small particulates containing allergens across production areas^[12]. Validation plans that don’t address top failure modes pass on paper but fail on the floor^[20].

Inadequate Changeover Documentation

Management pressure to minimise time between production runs results in changeover process failures. This guides to wrong packaging being used with incorrect allergen declarations or cross-contamination through inadequate cleaning^[12]. Changeovers require three documented stages: line clearance removes previously manufactured product, ingredients and packaging whilst cleaning the line; set-up brings new materials to the line and resets equipment; start-up confirms all activities are checked and signed off before the next production run begins^[12].

Insufficient cleaning between products creates potential for allergen cross-contamination, whilst incomplete line clearance allows previous product remnants to contaminate subsequent runs^[21]. Products packed into incorrect packaging rank as one of the biggest problems for FSA Allergen Alerts^[12].

Missing or Expired Training Records

Every employee including temporary and agency workers needs documented, role-specific training that remains current and signed^[11]. Training records serve as either the strongest defence or biggest liability during regulatory inspections. Sites lacking verifiable, organised documentation are viewed as noncompliant whatever the actual training quality^[22]. Records must show who attended, what was covered, when training occurred, and whether employees understood the material^[22].

Training documentation falls through gaps when companies rely on scanned certificates saved in folders with inconsistent naming conventions^[22]. Personnel and their protective clothing act as allergen cross-contact vectors unintentionally, which makes it critical that all personnel adhere to best practise processes and procedures^[23].

Poor Physical Controls and Signage

Coloured tubs used for wrong items, allergen cleaning signs missed when layouts move, and traceability confusion from handwritten notes that don’t match digital entries create serious audit issues^[24]. These behaviours might not cause problems in daily output but represent most important findings during audits. Inadequate physical separation or storage of commodities with different allergen profiles contributes to cross-contact risk^[10]. Movement between physically separated areas or dedicated equipment must be limited to avoid allergen cross-contact^[17].

Preparing Your Team for Unannounced BRCGS Allergen Audits

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Maintaining Allergen Control Documentation for Instant Access

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Conclusion

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References

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[3] – https://foodcore.io/blog/allergen-management-system-uk
[4] – https://safetyculture.com/topics/allergen-management/allergen-awareness-training
[5] – https://www.klipspringer.com/blogs/allergen-cleaning-validation-a-practical-guide-for-food-factories/
[6] – https://www.rssl.com/media/ayohzhst/rssl-white-paper-cleaning-validation-in-allergen-management.pdf
[7] – https://www.food-safety.com/articles/3812-allergen-validation-analytical-methods-and-scientific-support-for-a-visually-clean-standard
[8] – https://sgsystemsglobal.com/glossary/allergen-segregation-control/
[9] – https://oxmaint.com/industries/food-manufacturing/brc-audit-readiness-checklist-food-manufacturing
[10] – https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXC%2B80-2020%252FCXC_080e.pdf
[11] – https://www.alleratech.com/blog/brc-audit
[12] – https://www.foodnavigator.com/Article/2019/12/13/Top-ten-weakest-links-in-allergen-management-revealed/
[13] – https://safetychain.com/blog/essential-practices-for-brcgs
[14] – https://kellermanconsulting.com/episode-4-allergens-in-haccp-plans-and-preventive-controls-food-safety-plans/
[15] – https://www.fda.gov/media/129670/download
[16] – https://info.allergenbureau.net/infographic/raw-materials-storage/
[17] – https://www.fooddrinkeurope.eu/wp-content/uploads/2022/04/FoodDrinkEuropes-Guidance-on-Food-Allergen-Management-for-Food-Manufacturers-2022.pdf
[18] – https://www.fsai.ie/getmedia/2ad812a3-08d6-472c-8b95-470797502a0a/control_and_labelling_allergens_manufacturers-(1).pdf
[19] – https://farrp.unl.edu/sites/unl.edu.ianr.food-science.farrp/files/media/file/2008 English Components of an Effective Allergen Control Plan.pdf
[20] – https://sgsystemsglobal.com/glossary/allergen-validation/
[21] – https://www.brcgs.com/media/2164733/brcgs-foodissue8faqsjuly2020.pdf
[22] – https://www.linkedin.com/pulse/audit-failures-from-missing-training-documentation-keller-rgmse
[23] – https://www.campdenbri.co.uk/blogs/business-critical-allergen-management.php
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[25] – https://completefoodsafety.co.uk/blog/brcgs-unannounced-audits-how-to-prepare/
[26] – https://www.brcgs.com/media/rahl2upy/brcgs079-ps-and-protocol-on-unannounced-audits-meeting-the-gfsi-benchmark-v6-24-07-2024.pdf
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[31] – https://www.ifsqn.com/forum/index.php/topic/45276-brcgs-version-9-audit/
[32] – https://www.brcgs.com/media/2170588/allergen-mgt-22-sample.pdf
[33] – https://www.brcgs.com/media/2166654/p617-position-statement-for-allergen-management-control-v2-08012021.pdf
[34] – https://www.stevenstraceability.com/brc-traceability-requirements-guide/
[35] – https://teknomek.co.uk/blogs/all/nurturing-a-food-safety-culture-a-top-down-approach-for-brcgs-audit-readiness
[36] – https://www.cmx1.com/blog/gfsi-food-safety-compliance
[37] – https://foodsafetyguru.co.uk/the-ultimate-guide-to-allergen-management/
[38] – https://www.alleratech.com/blog/food-safety-audit
[39] – https://foodindustryhub.com/food-industry-knowledge-centre/know-allergen-controls/