You may be monitoring your facilities to prevent the accidental inclusion of allergens in the foods you prepare, but what about your ingredients supplier?
This is a question Debby Newslow has posed to clients for decades now, among many others, and with the Food Safety Modernization Act expanding evermore to encompass risks like undeclared allergens, it’s one she’s finding herself ask more often.
Newslow, president of D.L. Newslow & Associates, a food safety and quality management firm that specializes in auditing, consulting and training commissaries and other food facilities, says that now more than ever these simple, out-of-the-box questions are critical to establishing a prerequisite allergen program. Doing so is simply a matter of holding a microscope up to the world of potential cross-contact situations you may have — along your entire supply line — and putting preventative practices in place that will keep the worst from happening. And it’s firms like Newslow’s that are helping commissaries across the country to do so in preparation for FSMA’s compliance deadline in May.
“We had a client one time that had gotten a product from one of the leading providers of peanuts,” she recalls. “The product that they were buying was a non-nut product, but they were getting it from this company, and in their own process they didn’t use any nuts. So when we were in their warehouse, we saw this product and they said, ‘Well, it’s not a nut product.’ So we said, ‘Well, how do you know how it’s being manufactured?’”
It’s an important question — cross-contact can happen just through the dust in the air. Its tiny particles can cling to a worker’s clothes or be tracked in on their feet. And according to the Food Allergy Research & Education Association, food allergy reactions like anaphylaxis account for 200,000 emergency room visits a year and 200 deaths. And according to Mintel’s report Convenience Store Foodservice: US, one out of every 25 people that your clients sell your products to every day has a food allergy, making the prevention of cross-contact that much more imperative.
“This is where manufacturers really have to know what their ingredients supplier is doing and have confirmation from their supplier that things are what they’re supposed to be, that they are doing everything they can to prevent it,” Newslow says, noting that many suppliers of commissaries will provide an insurance letter or supplier guarantee of some kind, but an on-site visit to see things for yourself doesn’t hurt either. Basically, today’s commissaries and manufacturers should really do everything they can to protect themselves when it comes to allergen management.
Why? Undeclared allergens — those that were never intended to be a part of a food product in the first place — are the No. 1 cause of food recalls in the US. What’s more, Newslow says, over 90 percent of all of them are due to ineffective or nonexistent prerequisite food safety programs.
This is the new lexicon of the Food Safety Modernization Act, and what it means for the future of allergen management is prevention, prevention, prevention.
According to FSMA, cross-contamination is now defined as the unintentional transfer of a pathogen from one food or surface to another food or surface, and cross-contact is the unintentional incorporation of an allergen into a food. Preventing cross-contact, the resulting presence of undeclared allergens and the costly and disreputable recalls that follow are a key point of another aspect of FSMA, too — the evolution of Hazard Analysis and Critical Control Point plans into Hazard Analysis Risk and Preventative Control plans.
The difference, according to Newslow, is that while HACCP plans focus on analysis and control to minimize risk, HARPC plans focus on preparing for a much larger variety of risks and food safety hazards, including allergens. Thus a prerequisite food safety program can not only get you ready for compliance but ensure that it remains ongoing.
“Some people think the one plan will go away while the other takes over, but they’re really a combination of things,” Newslow says. “The HACCP always focuses on the critical control points — the critical point in the process where if you don’t control it you’re going to create a hazard or the likelihood of one, kind of like the difference between raw milk and pasteurized milk. However, because the majority of foodborne illness outbreaks are caused by prerequisite programs not being effective or not existing, we’re now coming into the Hazard Analysis Risk and Preventative Control, because it’s looking at things like allergen control.”
And lest we forget, everything you do should be documented down to the last detail in case of an audit.
“The big deal when you’re doing anything with food safety is not only that your programs are effective, but how you prove they’re effective,” Newslow says. “So having specific quantitative data that the government can use to substantiate what you’re doing — that’s something that we really recommend. It’s all about being proactive.”