Are Your Allergens Under Control? A Fresh Look at Food Recall Prevention
Are Your Allergens Under Control? A Fresh Look at Food Recall Prevention. Across the nation, food safety is a top priority for consumers and producers alike. Yet, despite robust efforts, the specter of food recalls due to undeclared allergens continues to haunt the industry. In fact, for the past five years, undeclared allergens have been the leading cause of recalls under the FDA’s watchful eye, as highlighted by a recent Sedgwick Brand Protection report.
This persistent challenge, coupled with the recent addition of sesame as the ninth major allergen under the FASTER Act, signals a critical need for the food industry to re-evaluate and strengthen its allergen management programs. The FASTER Act, by mandating increased surveillance and reporting on food allergy prevalence, could pave the way for an expanded allergen list and heightened regulatory scrutiny.
So, what can food manufacturers do to proactively prevent these costly and reputation-damaging recalls? While the basic principles of allergen control – from raw material identification and segregation to dedicated processing, scheduling, sanitation, and clear labeling – remain foundational, the industry’s ongoing recall issues suggest that it’s time for some fresh thinking.
Here are four key areas where organizations can build an additional layer of allergen recall prevention:
1. Educate Key Stakeholders: Beyond the Production Floor
Allergen management isn’t just a concern for R&D or the production team. Commercial teams and other groups involved in new product development or reformulations can inadvertently introduce allergens or affect processes that lead to cross-contamination. It’s crucial to include these stakeholders in staff training.
What you can do:
- Educate everyone on all allergens handled at your facility.
- Explain how product changes can impact production and allergen risk.
- Mandate clear communication about product changes within a set timeframe to avoid rushed decisions.
- Proactively discuss existing and potential allergen risks and explore solutions to ensure product launch plans account for proper allergen control.
2. Review Your Labeling Process: The Front Line of Allergen Communication
Labeling errors are a frequent culprit in allergen recalls. A thorough review of how labels are developed, changed, and inventoried is paramount.
What you can do:
- Require design staff to create easily identifiable labels using color blocking, unique identifiers, and icons for different product versions.
- Mandate clear and readable “Contains…” descriptions for both facility staff and consumers.
- Conduct a full label inventory, destroying obsolete labels and ensuring only current versions are accessible.
- Organize labels with dedicated locations, clear signage, and physical samples.
- Critically examine all storage and production areas to prevent mixed cases or pallets.
- Document and review the entire label change process: who is notified, how new labels are approved, and what controls are in place upon receipt.
3. Challenge Your Verification Activities: Proactive Problem-Solving
While traditional verification activities like record reviews and traceability exercises are essential, it’s time to go further. Challenge tests can reveal hidden gaps in your allergen program before a real-world incident occurs.
What you can do:
- Conduct mock challenges of your allergen management control plan, similar to food defense programs. Set up controlled scenarios, like an incorrectly stored label or a shortage of labels on the line, and observe how staff responds.
- Compare your monitoring activities to your verification activities. Are there additional checks that could catch an issue? Consider having the packaging operator be the qualified individual who checks every roll/case, with the QC team conducting hourly checks as verification.
4. Assessing and Changing Behaviors: Cultivating a Food Safety Culture to answer Are Your Allergens Under Control?
Many allergen recalls stem from a combination of inadequate programs and human error. A robust food safety culture empowers employees to make the right decisions every time.
What you can do:
- Conduct direct observations and interviews to understand staff’s current understanding of the allergen management program and their role in it.
- Ask “what if” questions: What would staff do if there weren’t enough people to clean the line, or if they ran out of labels during packaging?
- Develop improved programs and training that address these learnings, emphasizing the importance of effective allergen management to build competence and empower your team.
- Verify that any changes effectively eliminate or significantly reduce risk, embracing a mindset of continuous improvement.
Food manufacturers can significantly reduce their risk of an allergen recall by taking a fresh, proactive look at these areas – education, labeling, verification, and behavior. You can then answer, Are Your Allergens Under Control? It’s not just about compliance; it’s about safeguarding consumer health and maintaining the trust that is so vital in the food industry.