It's been 10 years since the Food Allergen Labeling and Consumer Protection Act (FALCPA) went into effect; still, unlabeled allergens continue to be the leading cause of food product recalls. To prevent a recall situation from arising, proper handling of allergens is paramount. This is at all stages of the food supply chain.

No business is too small to ignore allergen awareness.

Require awareness

Food allergen awareness is a universal requirement for anyone involved in the production, assembly, distribution and serving of food. Managing food allergens requires that all employees, even the office staff and the cleaning crew, be cognizant of the procedures to properly handle food allergens. This is because even trace amounts of a food allergen can cause allergic reactions for some consumers, with some reactions having the potential to be fatal. 

FALCPA identifies eight foods or food groups as major food allergens, as these allergens represent 90 percent of the food allergen incidents in the US. They are milk, eggs, fish (e.g., bass, flounder, cod, etc.), crustacean shellfish (e.g., crab, lobster, shrimp, etc.), tree nuts (e.g., almonds, walnuts, pecans, etc.), peanuts, wheat and soybeans. FALCPA is an amendment to the Federal Food, Drug, and Cosmetic Act and requires the label of a food that contains an ingredient that is or contains protein from a “major food allergen” declare the presence of the allergen in the manner described by the law. A simple statement such as “Contains wheat and milk ingredients” suffices.

Food allergens are a growing public health concern that affects an estimated 15 million Americans, including six million children. For those with a food allergy, sometimes even touching a food containing the allergen can trigger a reaction ranging from a mild response such as an itchy mouth or skin rash, to anaphylaxis, a severe and potentially deadly reaction that requires immediate medical assistance. Reactions to food allergens are responsible for 200,000 emergency room visits and as many as 200 deaths annually.

Food-allergic consumers rely on food labels to be complete, clear and accurate, as the presence of unlabeled allergens presents a significant health hazard. Further, an allergen recall presents an economic burden for all those involved in the production and distribution of the contaminated food.

All commissaries should include a food allergen awareness program in order to deal with this important matter. Such a program starts with identifying the presence of all food allergens in all ingredients that enter the facility. This requires working closely with suppliers to obtain detailed ingredient statements, including the potential presence of an allergen because a product was produced in a facility where an allergen is present.

Working with “local” suppliers and “family farmers” makes for a great marketing story, but also poses potential allergen safety issues, as many artisans do not have the resources to properly track allergens. Therefore, it is important to require letters from suppliers to guarantee the ingredients you purchase do not contain undeclared allergens. Require your suppliers to notify you of any changes to the allergen status of the ingredients they supply prior to any changes.

For example, the breads and rolls used to make sandwiches sold at the airport kiosk or the coffee shop counter may not contain eggs, but if they were made in a bakery that also produces baked goods made with eggs and tree nuts, there’s concern for contamination. One way to handle this matter is to declare this on the sandwich’s label. Possible statements include “This product may inadvertently contain eggs and tree nuts,” “Produced in a facility that handles eggs and tree nuts” or “Made on shared equipment with products containing eggs and nuts.” Such cautionary statements are not required by FALCPA, in fact, they are discouraged. Instead FALCPA emphasizes the importance of preventing contamination. Such voluntary labeling should be reserved for situations that potentially represent genuine hazards.

In recent years, there has been a proliferation of the use of precautionary allergen statements, desensitizing many consumers. This is especially true for teens and young adults who view these statements as often unnecessarily limiting their food choices. So instead, they take a chance on their life.

Maintaining records

A food allergen awareness program should identify points during food assemblage when contamination can occur. Properly labeled and segregated ingredients can assist with preventing contamination. Review the labels of incoming raw materials for the appropriate allergen information or any changes. Tag each incoming container to ensure the allergen is clearly identified in order that the product is properly stored and used in the commissary.

Most food allergen contamination results in mislabeled product and mislabeling is the number-one cause of food allergen product recalls. One of the best ways to prevent allergen contamination is to produce allergen-containing products on a different day than the non-allergen containing products. Another option is to produce the allergen-containing products at the end of the day, after the non-allergen-containing products have been packaged and removed from the production room.

Daily production records and records of manufacture also help prevent contamination. Such records inform production personnel on the products to make, the sequence of production and the ingredients to use, or not to use, in each product. Record all ingredients and their lot number on the record of manufacture as well as the lot numbers of all food-contact packaging materials. The finished product should include a manufacturing date and facility code in order to assist with tracking product in case of a recall.

Finally, cleaning and sanitation are extremely important in preventing food allergen problems. In a commissary, this is more about work space and utensils than stainless steel vats and valves. If equipment is left dirty or is not properly cleaned, the residues may contain enough of a food allergen to get carried through to the finished product and cause an allergic reaction.

A food allergen awareness plan is a continuous effort. Every time a new ingredient enters the facility, this includes same ingredient but new supplier, or new menu item is being assembled, the plan must be updated. Every time a new employee is hired, they must be educated.