Food Allergen Recall - Who's Next?

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.

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RQA Europe Food Allergen Management Services

1. The RQA Allergen Awareness Training

The training is applicable for:

Production, Technical, Quality - Managers, Supervisors and Operators

The training programme:

Allergen related legislation
Allergy and intolerance - symptoms and reactions
Consideration of existing company policies
Exercise - Where are the allergens?
Allergen risk assessment - FSA decision tree approach and advisory labelling
Exercise - Allergen risk assessment
Allergen related recall examples
Allergen risk management and controls
Analytical testing - possibilities and practicality
Exercise - Allergen risk management
Allergen auditing and HACCP - Guided discussion
Exercise - Prepare a checklist for allergen auditing
Allergen communication and training - Guided discussion

2. The RQA Consultancy services

We provide a range of consulting services to help you prevent as well as prepare for food allergen related incidents. RQA experienced consultants can advise you on any aspect of the food allergen labelling and provide training to minimise a risk of product becoming contaminated with undeclared food allergens in the future.

"Traceability Challenge" exercise - tests the traceability of major and minor ingredients at each stage of the manufacturing process, including work-in-progress. We focus on all areas of your production process to ensure that you are compliant. This exercise minimises the risk of undeclared allergens in your products.

Crisis Response Line - We operate an around the clock Crisis Support Help Line that can be tailored to your business needs. This advice, which can be provided by a consultant over the telephone or via onsite visit includes:

Risk Assessment
Traceability
Assistance with Lab Testing
Current Recall Legislation
Advice on Informing Customers/Local Authorities
Recall Log
Post-incident Analysis and Prevention Advice

Consumer Complaint Collection - RQA can arrange for a product to be collected from a consumer within 24 hours of notification and can ensure that they are sent back to you or a lab for rapid testing and investigation.

Product Withdrawal - If products need to be removed from point of sale in an independent retail stores, RQA's field representatives can be rapidly mobilised to achieve this. This minimises the risk of incidents that may be reported to your company due to consumers purchasing products with undeclared allergens.

To find out more how RQA can help you with the issue of food allergen management and food allergen labelling please click here to contact us.

8GB Ipod Nano - the latest prize for the quarterly draw for subscribers to our monthly recall newsletter

RQA introduced a quarterly prize draw for subscribers to our monthly newsletter in September. The prize for the first draw, held in September, was the latest Nintendo Wii Console (Included Wii Sports) and the winner was an employee of Robert Wiseman Dairies. The new prize draw for December is the IPod Nano with 8GB or space for 2,000 songs / 8 hours of video.

The new exciting prize draw is open to everyone who is signed up for our recall newsletter (excluding employees or contractors of RQA). The subscriber names will be entered into the prize draw and one lucky prize winner will be selected. The winner will be announced on 18th December 2009.

Please feel free to inform any of your colleagues who might be interested in the RQA recall newsletter and would like to be entered into the draw. Click here to sign up for our newsletter.

Create your own recall plan within hours.... An online plan designed by us and customised by you!

The RQA Crisis Plan Toolkit helps you to create your own recall plan online and is already widely used by RQA clients. Enabling you to meet the product recall requirements of BRC and IFS, the online toolkit can be purchased for £400 / €475.

The RQA Online Crisis Toolkit consists of a skeleton recall plan to help companies that do not have a plan to develop one. It is a step by step guide including tips and example text based on industry best practice and considering the requirements of BRC. You can even use this to benchmark you existing plan.

Easy to update.....For example, if you need to update the recall team contact details, you can do this online and then reissue your plan to your distribution list at the click of a button. It couldn't be easier!

A pandemic flu plan for the toolkit will be available during December.

Click here to contact RQA Europe or go to http://www.crisisplantoolkit.com/ to purchase the plan.

Case Studies

Product Recall Solutions
food industry

Product Sesame seed Incident Salmonella Country Germany Date 05/11/2009	Sesame seeds, imported from India have been withdrawn from Germany due to the contamination with Salmonella. The products have already been distributed to Austria and Germany, but no illnesses have been reported yet. The manufacturer has voluntarily withdrawn all affected products.
Product Chocolate bars Incident Foreign bodies Country United Kingdom Date 03/11/2009	Chocolate bars sold in the UK are being recalled from consumers by the distributor. The reason for the product recall is that plastic fragments have been found inside some of the chocolate bars. Consumers were advised to return the product to the place of purchase for a full refund or replacement product. The distribution of the affected chocolate bars has been restricted to the UK and the alert was posted on the European alert system (RASFF).

Product Sesame seed
Incident Salmonella
Country Germany
Date 05/11/2009

Sesame seeds, imported from India have been withdrawn from Germany due to the contamination with Salmonella. The products have already been distributed to Austria and Germany, but no illnesses have been reported yet. The manufacturer has voluntarily withdrawn all affected products.

Product Chocolate bars
Incident Foreign bodies
Country United Kingdom
Date 03/11/2009

Chocolate bars sold in the UK are being recalled from consumers by the distributor. The reason for the product recall is that plastic fragments have been found inside some of the chocolate bars. Consumers were advised to return the product to the place of purchase for a full refund or replacement product. The distribution of the affected chocolate bars has been restricted to the UK and the alert was posted on the European alert system (RASFF).

Product Recall Solutions
consumer products

Product Rattle toy Incident Risk of choking Country Cyprus Date 13/11/2009	Following an official control by the authorities in Cyprus, a manufacturer has withdrawn its product from the market due to a risk of choking. The reason for the product withdrawal is that the toy can easily break releasing small parts that could be swallowed by small children. The product does not comply with the Toys Directive and with the relevant European standard EN 71.
Product Travel mugs Incident Burn hazard Country United States Date 06/11/2009	An American manufacturer is voluntarily recalling its consumer products from the market in the USA. Consumers were advised to stop using recalled products immediately. The travel mugs can become excessively hot to the touch when filled with hot liquids, posing a burn hazard to consumers. The company has already received three reports of excessively hot mugs, including one complaint of a minor burn to the hand. The U.S. Consumer Product Safety Commission has published the notification on it website.

Product Rattle toy
Incident Risk of choking
Country Cyprus
Date 13/11/2009

Following an official control by the authorities in Cyprus, a manufacturer has withdrawn its product from the market due to a risk of choking. The reason for the product withdrawal is that the toy can easily break releasing small parts that could be swallowed by small children. The product does not comply with the Toys Directive and with the relevant European standard EN 71.

Product Travel mugs
Incident Burn hazard
Country United States
Date 06/11/2009

An American manufacturer is voluntarily recalling its consumer products from the market in the USA. Consumers were advised to stop using recalled products immediately. The travel mugs can become excessively hot to the touch when filled with hot liquids, posing a burn hazard to consumers. The company has already received three reports of excessively hot mugs, including one complaint of a minor burn to the hand. The U.S. Consumer Product Safety Commission has published the notification on it website.

RQA Europe Limited
Science and Technology Centre
Earley Gate
Whiteknights Road
Reading RG6 6BZ
Tel 44 (0)118 935 72 42