Food Allergen Recall – Who’s Next? – 20/11/09
The undeclared presence of major allergens in foodstuffs has become a significant cause of product recalls and withdrawals. Whilst many companies have developed effective recall procedures, the most successful and cost effective recall is the one that is prevented, and so the purpose of this article is to point out some measures that can be taken to minimise the risk of undeclared allergens. This article will cover issues related to incorrect product labelling. Problems relating to products becoming contaminated with undeclared food allergens will be covered in a future article.
The incidence of food allergen sensitivity in the populations of the so-called developed world has increased markedly during the latter part of the 20th century and up to the present day. The reasons for this are still speculative and a significant amount of co-ordinated research into the causes and effects the phenomenon is now taking place around the globe. An example is the EuroPrevall Project, which is an EU-funded multidisciplinary project that involves 63 partners in 17 EU states together with Switzerland, Iceland and Ghana.
As a result of this rise, and the seriousness of allergic reactions suffered by some individuals, legislation has been enacted to ensure that the presence of major food allergens is indicated on the labelling of pre-packed foods. In the EU this is covered by European Directive 2003/13/EC (as amended), which specifies the 14 major food allergens for which labelling is compulsory. Similar legislation exists in many non-EU countries where pre-packed foods are marketed widely, e.g. USA, Japan, Australia, although the food allergens that are specified in the legislation may differ to some extent.
In many cases the use of incorrect packaging or labelling is the cause of incorrect allergy information. This can be caused by incorrectly printed label information or the use of the wrong label on a product. Ensuring that label information is accurate during the design of product labelling is clearly a key factor and a structured protocol for checking (and double checking) label information before final approval prior to printing is vital. Where new products are concerned, labels may well undergo development before the product specification is finalised and it is all too easy for a late tweak to the formulation to be missed from the label if short cuts are taken.
The use of very similar label designs for product variants increases the potential of operator error in applying the wrong label or wrapper, which may have incorrect allergen information. If similar labels are really necessary, e.g. for design consistency, more stringent label checking procedures in production may be necessary. This may involve multiple visual checks and sign-offs before commencing packing after a product change-over and/or the use of bar code scanning to verify that the label matches the product being packed. In any case it is good practice to retain a sample label with the line records for each product batch produced for independent verification and for checking in the event of any issue raised at a later date.
The use of line clearance procedures on packing lines when changing between products that may have different allergen ingredients is also an important control method to avoid incorrect allergen labelling. Use of a checklist to remind personnel to ensure that the only labels in the vicinity of the line are the correct ones for the product about to be packed and also that all products from the previous run have been removed may help to eliminate labelling error. Based on risk assessment it may be considered good practice for the operator to check and for it to be verified by a team leader or other responsible person.
When changing packaging as a result of product reformulation involving allergen ingredients, companies need to consider whether this needs to be clearly signalled by on-pack flashes and possibly use of other promotional information, such as shelf displays. This is because consumers with allergen sensitivity get to know the products they can safely eat and so many will not check the pack label before they purchase their regular products. If an allergenic ingredient is included that was not previously used, the use of clear "New Improved Recipe" or similar flashes will help to alert such consumers so that they will check the ingredient label or "allergy information panel'.
Although there are still many questions about food allergies to be answered, there is now a good deal of up-to date information readily available from reputable websites and below is a small selection of useful links.
www.food.gov.uk/multimedia/pdfs/maycontainguide.pdf
www.ifst.org/science_technology_resources/for_food_professionals/information_statements/ - see Information Statement on Food Allergens
http://allergytraining.food.gov.uk/english/
www.foodintoleranceawareness.org/default.htm
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