Are You Suffering From Undeclared Allergens?
Many of us have either a family member or friends that suffer from a food allergy. Listening to their stories of how disciplined they must be on a daily basis in order to avoid injury is absolutely amazing. The things that I take for granted, such as walking into a convenience store to pick out a quick snack for my son aren’t so simple and quick if you have a loved one that suffers from a food allergy. Everyone working in the food industry from the plant manager to the temporary employee truly needs to have the same level of discipline each and every day because we are responsible for the well-being of our consumers in preventing undeclared allergens.
Approved supplier systems often get either overlooked or viewed as a system just to collect documentation. The approved supplier program is a key part of preventing undeclared allergens in facilities and understanding the level of risk suppliers place on finished products. Issuing questionnaires in order to understand what allergens raw material suppliers have in the facility is an important piece of the program. Once everyone understands what allergens are in the plant, they then can pay close attention to the third party audit results to understand how effective the suppliers are in the areas of sanitation, changeover controls, label review process, and training.
Improper labeling is the biggest cause of recalls in a plant. A strong label program includes:
- A review process for each lot of labels received into the facility. Place all labeled products on hold until a documented review has been completed by a qualified individual. Have a master binder(s) containing all approved labels and utilize a checklist to include all areas of the label to review. This will ensure consistency when multiple reviewers are being used in the facility.
- A formal process of how labels are issued to the production floor. This should include restrictions that do not allow multiple product labels on the floor in the same vicinity at the same time.
- A well-documented changeover process. The changeover process should include the requirement that all packaging be removed from the line prior to issuing any new packaging. Have a formal inspection of the line prior to issuing the new packaging or labels to ensure all product and packaging have been removed from the area.
- Documented verifications. Periodically verify the documentation on the products throughout the production runs to ensure you have the right label on the right product.
Sanitation procedures need to be documented on how to adequately clean the equipment in order to remove the allergen protein from equipment surfaces. Oftentimes, plants utilize a mid-shift clean up as part of the changeover process. Make sure that these cleaning processes are also documented in a formal sanitation program because the cleaning processes may differ. Take periodic line swabs to validate these cleaning procedures to ensure they are effective in removing the allergen proteins. Include non-contact surfaces as well (sides of equipment, control buttons, estops, etc.) so you understand the cleaning effectiveness of these areas.
Ensure the allergen program also focuses on the little things, which are often overlooked in plants. An example would be employee rotations. It’s common that the line employees stay on a particular line and do not rotate, which could cause allergen cross contact. Pay attention to the supporting departments such as QA, maintenance, and even operation leads or supervisors. These employees tend to move and work with multiple lines, which could increase the risk of allergen cross contact. Establish a system where the QA department conducts line inspections on non-allergen products first, then conduct inspections on allergen products, and finally washes hands and changes garments before starting the cycle over again. A robust maintenance program includes equipment cleanup procedures for contact and non-contact pieces of equipment to prevent the potential for allergen cross contact.
Every department and individual in the plant has a role or is involved in the overall process to prevent undeclared allergens in food products. An effective training program is a critical tool for preventing undeclared allergens. An effective training program needs to ensure not only that all employees are trained prior to working in the plant but also a verification that the training was effective. Remember, it only takes one employee to cause a recall. Include exams during or at the conclusion of the training process to ensure all employees understand their responsibilities and the details of how to prevent undeclared allergens in your facility.