Recalls are the last resort in our food safety network. To say they are undesirable for both consumers and businesses is an understatement. The cost to any business can be hundreds of thousands of dollars, and the damage to consumer confidence possibly even higher. Yet at the last count, the number of recalls in Australia and New Zealand for foods associated with the presence of undeclared allergens was once again in the thirties, with December still to go.
The Allergen Bureau has a very large collection of information aimed at manufacturers to help them reduce the chance of a recall in their business. As we come into the festive season, it would be wise to recap on some of the reasons recalls can occur and the resources that are available.
1 – Incomplete Ingredient List/Label (missing an intentionally present allergen in a component, ingredient, processing aid or a compound ingredient <5%)
- Understanding the requirements for allergen labeling – both regulatory and best practice. The FIGAML resource will help.
- Have a formal review/approval process for label artwork by a competent technical person checking allergen declarations & claims. If you are not sure how to do this, check out our Allergen Risk Review Website (ARRW).
Label artwork – Allergen Bureau Info Site
- Request Specification / Product Information Form (PIF) for every ingredient, but don’t assume PIF details are always correct.
- Seek confidence in supplier information and allergen knowledge.
Specification assessment – Allergen Bureau Info Site
- Ask questions about potential unexpected allergens in Food e.g. Processing Aids. See our guides Unexpected Allergens in Foods & Assessing Agricultural cross contact risks.
Allergen Bureau Resources – Allergen Bureau
- Ensure processes are in place to manage updated Specification / PIF details when changes occur.
2- Incorrect Claims (Claimed to be free from a certain allergen(s), however ingredient(s) used in the product contain that allergen(s)).
Please take a moment to consider some of the best practice controls related to “Allergen Free” Claims, and Analysis, many of which can be found in FIGAML (Section 4.3):
- The Food Standard Code does not have specific requirements for making “allergen free” claims, so the criteria for making claims falls to each company and consumer laws.
- The exception is “Gluten-Free” which is a nutrition content claim, the conditions of which are set out in Standard 1.2.7 and Schedule 4.
- See Allergen Bureau FAQ’s,
– Can I make a Gluten Free Claim on my product?
– Can I make an Allergen Free Claim on my product?
- In many regions of the world, including North America, the EU and countries that adopt Codex Alimentarius standards, the limit for “Gluten Free” food is ≤20 ppm gluten, which does not meet the standard for “Gluten Free” in Australia and New Zealand.
- “Allergen free” and “Gluten Free” claims should be supported by documented evidence of the controls and measures in place.
- Where possible, relevant and appropriate analysis should be applied to support these claims. For more information on analysis please refer to our website.
Food Allergen Analysis – Allergen Bureau
- The allergen should not be detectable in the food using an appropriate method of analysis. Analysis has a critical place in supporting allergen management but is not a substitute for a robust allergen management plan. A clear understanding of the limitations that may be associated with analysis is important in method selection and result interpretation.
- Have a formal review / approval process for label artwork by a competent technical person checking allergen declarations & claims.
Label artwork – Allergen Bureau Info Site
- Accidental Cross Contact from the Production Process.
Please take a moment to consider some of the best practice controls relating to cross contact elimination or reduction from production. Many tips for assessing the risk from cross contact in the supply chain can be found on the Allergen Bureau ARRW.
- Production Scheduling supported by an allergen matrix which determines the best production order to minimise cross contact, and decrease product change overs.
- Ensure SOPs to manage allergen cross contact include instructions for any alterations to scheduling e.g. Formal authorisation steps from a person who has a very good technical understanding of the impact of the change.
- State the allergen status on daily schedules, so rationale is clear in case of break downs or, production teams need to deviate from the schedule unexpectedly.
- Cleaning equipment, preparation areas and the production lines of a food manufacturing site is necessary to eliminate allergen residue and the potential for cross contact
- Consider Hang Up points in pipework, pumps, mixers, conveyors, utensils etc.
- Implement a cleaning schedule which outlines the methodology and frequency of the cleaning program.
- Cleaning validation, supported by the collection of evidence, that the cleaning processes are effective in removing the allergenic protein from the equipment or line etc.
- Cleaning verification activities to check that the cleaning steps are taking place and are meeting the standard.
- Spills of allergenic material are cleaned up promptly, and correctly disposed of.
- Cleaning personnel are trained, experienced and consistent.
- Dedicated colour coded cleaning tools for allergen cleaning.
- Cleaning tools and equipment are also cleaned to prevent allergen cross contact.
- Staff are trained, and assessed, in their understanding food allergens, the risk to consumers with food allergy, the identification of cross contact allergens and the management of food allergens.
The Allergen Bureau has a free helpline available to the food industry. If you are uncertain about how to tackle a task or about the answers you receive back from suppliers, please contact us at .firstname.lastname@example.org.