Allergen Control

Undeclared allergens result in the highest amount of food recalls in the US annually.  Although the number of recalls for this category has decreased year over year, it is still important to develop a program that manages this food safety threat.  90% of food allergic reactions are covered under what the US Government calls the “Big 9”:

1. Crustacean shellfish (e.g., crab, lobster, shrimp)

2. Eggs

3. Fish

4. Peanuts

5. Milk

6. Tree nuts (e.g., almonds, pecans, walnuts)

7. Soybeans

8. Sesame

9. Wheat

Labeling

The US government requires that allergens must be clearly declared on every label of food products produced.  An effective program has a strong verification process that ensures allergens are plainly listed/contained in the ingredient statement of the final product.  Best practice would include a daily review of the ingredients used in the finished product to ensure that the supplied ingredients don’t have new components/allergens that would not be declared on the finished product label.  Another option would be to conduct the label comparisons (ingredient labels to finished product labels) with each Lot change on an ingredient. 

Although reputable suppliers should notify their customers of changes to the ingredients supplied, if this does not occur then the daily/lot review will identify the error before producing large amounts of product with an undeclared allergen.

Scheduling

One of the best ways to prevent allergens from being introduced into finished products is to schedule production, post-sanitation, from order of no allergens to products containing allergens.  Allergens present in products being produced must match the same allergen(s) as the product produced prior.   Example:  Item 1 – no allergens, Item 2 – Wheat, Item 3 – Wheat & Milk

Sanitation

The frequency and type of sanitation process regarding allergen control should be validated to prove effectiveness at the removal of allergens.  The way to do this is to purchase allergen testing kits for each type of allergen present in products that the facility produces and structure a study for each type of allergen following the production and cleaning processes.  The studies should be performed on food contact surfaces and documented not only for facility use, but also for audit or government requests.

Cross-contamination Prevention

Each production line with differing allergens should have its own color-coded or identifying tools and containers to demonstrate what is utilized on that specific processing line.  This includes having dedicated storage areas for team member smocks, gloves/aprons, etc. for each production line. 

The purpose of a color coding/identification system is to prevent cross-contact from use of these items by team members on other lines thereby allowing the movement of the allergen to a line/area that does not have it declared on the finished product packaging. 

As a side note, air flow and equipment such as pallet jacks should be reviewed as potential modes of cross-contamination and included in any validation studies if considered to be a cross-contamination risk.

Training

As with any key food safety programs, allergen program controls should be included in new hire orientation and with annually training thereafter.

In conclusion, effective allergen control is essential toward protecting the company brand and preventing costly recalls due to undeclared allergens.  Although factory control elements are important toward this endeavor, the use of highly competent suppliers of ingredients with very robust allergen programs should not be underestimated toward success in this area of food safety.