A quick review of product recalls and withdrawals in any given week reveals that allergens, and the need to declare their presence in foods, represent a massive challenge for the global food industry. In one week’s recalls in the United States, for example, inaccurate labeling resulted in the recall of sandwich rolls (undeclared milk), ice cream (undeclared almonds), salmon spread (undeclared egg), and ice bars (undeclared milk). No category of processed and packaged food is invulnerable to the risk of mislabeling, and no food product is immune from the possibility of giving an incomplete description of ingredients.
If the risk is great for the average food company, then it is arguably greater still for those manufacturers in the “free-from” sector. For these companies, it is never merely a question of complying with labeling legislation. Rather, consumers are relying on the accuracy of any free-from statements to protect their health and ensure they are buying food suitable for their needs. The consequence of mistakes is potentially very serious, both to consumer health and to the reputation of the manufacturer.
It is especially important that free-from producers properly understand the ingredients they use and the way those ingredients have been processed to justify any free-from claims they might wish to make.
The legal responsibility for accurate labeling rests ultimately with the manufacturer, but the practical responsibility extends throughout the supply chain. Whether the manufacturer is in the free-from sector or not, suppliers will be favored if they are willing and able to show they have the necessary controls in place to manage allergen risk in their factories. Ingredient suppliers that are willing to work with manufacturers and share information will be best placed to secure long-term contracts.
As the best documented and most potent of all allergens, nuts can be used to illustrate many of the issues that must be addressed when producing a free-from product. This discussion starts with definitions. Peanuts, for example, are not nuts at all. They are legumes, more closely related to peas and soya. Few of us would argue, however, that a nut-free product might legitimately contain peanuts; it matters both how statements like “nut-free” are used and how they are understood by consumers. Similar potential difficulties arise in defining eggs, crustacea, milk, and other allergens that may be used.
This is not merely a question of semantics. It is absolutely fundamental that ingredient suppliers and their customers fully understand what is being supplied and know what other ingredients have come into contact with those supplies as a consequence of either storage or processing. It is equally dangerous to assume that consumers will recognize that a certain type of product will always contain a certain ingredient (e.g., milk as an ingredient in parmesan cheese). When it comes to allergens, assumptions, misunderstandings, and the absence of even a small piece of information are likely to lead to problems.
An Allergen-Free Strategy
To avoid the unintentional presence of any allergen in a product, evaluate all routes of likely inclusion, both deliberate and accidental. This is most effectively accomplished using hazard analysis and critical control point (HACCP) principles, with which most manufacturers should be familiar. All critical control points must be documented—and controls put in place—to prevent contamination, with internal auditing used to ensure their efficacy.
Most food and ingredient producers already employ good manufacturing practice (GMP) to ensure safe food production. GMP requires appropriate manufacturing operations, effective food safety systems linked to HACCP-based principles, and quality assurance systems, as well as commitment and discipline to ensure that products meet food safety, quality, and legal requirements. With respect to “allergen-free” manufacture, the following factors need to be considered:
- training and communication;
- raw materials and supply chain;
- monitoring and review;
- plant sanitation;
- manufacturing premises, equipment, and processes; and
All of the above areas need to be covered by detailed standard operating procedures (SOPs) in order to guarantee uniformity in practice.
Training and Communication
Education is key to allergen control, and all employees must be fully committed to the policy and aware of the implications of failings. Training sessions should be tailored to meet the specific operational sectors of the organization and should include temporary staff and contractors. For example, those involved in handling ingredients, equipment, utensils, packaging, and products should be trained in:
- potential allergen cross-contamination situations;
- hand washing;
- clothing requirements;
- waste control;
- cleaning procedures;
- dedicated equipment use; and
- general good housekeeping.
Training messages should be backed up with clear signage so that all employees and visitors are aware of the site’s allergen control policies. Refresher training should be completed at set intervals.