Food allergens: best practices to protect the consumer

5.0.2Despite food manufacturers’ best efforts, undeclared allergens, that is, food allergens not declared on a food’s label, are the leading cause of food recalls requested by the U.S. Food and Drug Administration (FDA). Undeclared allergens may result from cross-contamination, placing the wrong label on a product, or a manufacturer not being aware of the need to label a certain ingredient.

When an allergen is undeclared it poses a major threat to the 15 million Americans who suffer from food allergies—a number that has risen over the past several years, especially among children. Because there is no known cure for any type of food allergy, a recent article explains the regulations and best practices food producers can take in order to protect their consumers.

First, the article states the importance of fully knowing the regulations around the labeling of food allergens. In 2004, the Food Allergen Labeling and Consumer Protection Act (FALCPA) created industry standards mandating that the labels on food products prominently display the presence of any ingredient from one of the eight major food allergens—peanuts, eggs, milk and milk by-products, wheat, tree nuts, soy, fish and shellfish. These allergens account for 90% of all documented food allergies in the U.S.

The most recent regulations to address food allergens were established by the Food Safety Modernization Act (FSMA), which was signed into law in 2011. This legislation represents the most sweeping change to food safety regulation since the 1930s and represents a more proactive approach to food safety by preventing incidents of contamination before they occur.

The final rules of the FSMA are set to be published by FDA this month but at this point the clock starts for business of all sizes to reach compliance. Large businesses will have one year from the posting date to comply, medium-sized businesses will have two years, and small businesses will have three years.

In all, allergen control is an important aspect of FSMA. The law is expected to result in updated Good Manufacturing Practices that will likely impact sanitary equipment design requirements as equipment manufacturers shift their focus to include allergens as well as microbial pathogens. Identifying and implementing preventive control rules is another area in which FSMA will address allergens, the article states.

In addition, some of the earliest and most significant impacts on food producers are expected to come from preventive control rules. Operators will need to understand any allergen hazards likely to occur in their operation and have measures in place to minimize or eliminate them. Ultimately, every facility in the food supply chain will be required to implement a written food safety plan that includes food allergen controls.

Another extremely important aspect in food safety is preventing mislabeling and cross-contamination. Professionals responsible for food manufacturing operations must ensure the label lists any allergen found in a product. To prevent mislabeling, the article states that food producers can use vision inspection systems to confirm that a label is matched accurately with its respective product.

Addressing the second concern, cross-contamination, involves preventing any contact between products that contain allergens and those that do not—especially for products used as ingredients in the production of other foods. This, however, is often difficult to address and involves supplier attention and control—an important and relatively new concept to allergen labeling. Whether manufacturers source ingredients domestically or internationally, it is crucial that they’re on the same page with their suppliers. Manufacturers need to know all other products found or produced in a supplier’s facility and whether those products contain allergens.

For example, if a supplier of corn flour also makes wheat flour in the same facility, it is incumbent on the manufacturer to verify that the supplier is taking the necessary precautions to prevent cross-contact between the two ingredients.

For imported ingredients, FSMA places responsibility and liability on the business importing the food to ensure its safety. The Foreign Supplier Verification Program, mandated by FSMA, will require the importer to maintain a list of all foreign suppliers and to develop a Hazard Analysis for all imported food products, the article states.

Above all the article stresses the importance of staying ahead of the curve though education on the upcoming regulations and rules that FSMA is likely to incorporate. For instance, Hazard Analysis and Critical Control Points (HACCP) is a systematic preventive approach to production processes that designs measurements to reduce risk in a facility. HACCP has many parallels to the upcoming preventive controls rules found in the FSMA and manufacturers can ease the transition into the new laws by formulating and adopting programs now.

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