A “life-threatening” food safety recall was announced by the FDA in late June, following the discovery of undeclared milk allergens in semi-sweet chocolate Nonpareils sold across eight states on the East Coast. It was just one of a total of 6 recalls issued for undeclared milk in chocolate products sold by several companies across the country.
“As a company, we’ve always had two sets of eyes. We have the person who does the task and the person who checks it, and they can’t be the same person. You need another set of eyes,” Betsy Craig, the Founder and CEO of MenuTrinfo told Rootwurks.
MenuTrinfo provides food facility audits through its Certified Free From (CFF) program, the only global certification that verifies that retail and packaged foods are free from major allergens. The company also offers food allergy and gluten-free training and nutritional consulting.
“You can pay me $5,000 a year or pay hundreds of thousands of dollars on a recall when you have an incident,” Craig explained.
The company uses a variety of methods for testing, including immunochemical methods and lateral flow devices (LFD). The company favors LFD testing paired with visual inspection of cleanliness as an effective method of allergen residue monitoring.
In 2023, the FDA reported that undeclared allergens were the reason for almost half (49.3%) of food recalls, far ahead of listeria contamination (15%) and salmonella contamination (8.6%). The FDA stated that the rise in allergen-related recalls can be linked in part to the inclusion of sesame as a disclosed allergen, representing 39% of the increase.
Craig said the relatively recent update doesn’t explain the high number of allergen-related recalls.
“The recalls aren’t because of sesame, they’re because they got something wrong. They used the wrong ingredients, or the wrong label or packaging. Or they had accidental cross contact or used a production line with peanuts to make a non-peanut produced product, but didn't do all the cleaning properly.”
Craig said that most allergen recalls occur for one of two reasons: either the product is mislabelled and doesn’t declare that it contains a specific allergen, or the allergen was introduced into the product during the manufacturing process.
She added that these incidents can happen even to the biggest, most well-run companies.
“It happens at all different-sized companies, from tiny ones to massive companies, from ones that have one quality assurance person to ones with teams of quality assurance personnel, it still happens.”
The key step in allergen prevention is to develop and maintain a strong food allergen control plan. An allergen control plan lays out the specific, systematic steps a company must take to identify, control, and prevent undeclared food allergens.
Under the guidelines of the Food Safety Modernization Act (FSMA), food companies must perform a hazard analysis to identify potential hazards to human foods, including food allergens. There are several key steps to an allergen control plan, including review of the product flow during the production process to prevent cross-contamination, separation of allergenic foods from non-allergenic foods, allergen identification and labelling, and the implementation of carefully designed production and cleaning schedules for the facility. The company must train employees on the guidelines for carrying out the plan, and the effectiveness of the allergen plan must be regularly reviewed.
“Companies have an allergy control plan and they must follow it, and if somebody is missing a step, you need to try to figure out where it happened and not let it happen again,” Craig said, adding that a company should review its allergy control plan at least once every quarter.
She also recommended that companies have a third party come in to review their allergy control plan to gauge its effectiveness with a fresh set of eyes. She said companies should have at least two checks on the backend for product labels, which she said would probably remove about a third of the recalls.
She added that to be declared free from allergens, a company should be testing ingredients upon entrance to their facility and have notations in their purchasing contracts that ingredients will not introduce an allergen.
Beyond the allergy control plan, Craig said there are specific safety principles that every company should implement.
“If you have good GMPs [good manufacturing practices] for cleanliness and changeovers at the end of shift, you’re probably in good shape. Training your team on what allergens are gives them another level of awareness.”
She added that because of our very nature as humans, it is essential that companies follow their allergy prevention procedures with vigilance.
“It's human error and humans are humans."
To train your team for allergen control and recall prevention, enroll in the Rootwurks Allergen Management Training for Food Safety course, available now for only $34.99.
You can also hear more from Betsy Craig in the on-demand Rootwurks webinar "How to Prevent Allergens and Safeguard Your Company," now streaming here.