When most people hear about a food recall, the first thing that comes to mind is foodborne illness — listeria, salmonella and E. coli being the usual suspects.

But many recalls are the result of food mislabeling, in particular the failure to disclose food allergens. In September alone, three U.S. companies recalled grocery deli or bakery products because of undeclared allergens. And even if no one gets sick, every recall has the potential to inflict major damage on a company’s bottom line. An Ernst and Young survey of manufacturers showed that 47 percent estimate the total cost in both sales and direct costs of recall to be $30 to 39 million. Eight out of ten respondents described the overall financial con­sequences of a recall as “significant” or “catastrophic.”  

Failure to disclose allergens is one of the biggest mislabeling problems in the food industry, says Joanna Mooberry, market segment manager for Aurora, Illinois-based Mettler Toledo CI-Vision, a division of Columbus, Ohio-based Mettler Toledo. “Forty percent of product recalls involve allergens,” Mooberry says. “It’s a high number. Mislabeling is really a big issue.”

It can be particularly tricky, Mooberry says, when a product contains more than one label. A product containing multiple units, for instance, often has an ingredients label on the outside packaging and one on each individual unit. Craft manufacturers also are more exposed to labeling errors if they need to frequently change labels by hand as product changes, she says. “They have a lot of product changeovers because they want to maximize the time they have their production up. It creates a lot of issues.” Product changeovers, she says, typically need to be executed as quickly as possible. That means operators must often scramble to refill or change labels, raising the risks of mistakes occurring.

Another problem is equipment malfunction, which is slightly less common than human error, but no less disastrous, according to a Mettler Toledo white paper. Printers perform multiple runs of the same label design as manufacturers need them, which creates the risk of slight variations in each individual run. The slightest printer error can prevent important information from being included on a label. “For example, a printer may run low on ink, resulting in a missing allergy warning,” according to Mettler Toledo.

Mettler Toledo CI-Vision makes vision inspection systems that examine labels for errors and help ensure that labels match the contents of their products, Mooberry says. The “100% uptime” the computerized system provides is a big improvement over checks by a human being, she says. Manual inspection can’t keep up with production line speeds of 1000 parts per minute or more, yet some manufacturers still only rely on manual inspection to protect themselves from product defects such as label mix-up.

One recent upgrade to the system, Mooberry says, is the ability to detect errors in ink jet print, which is notoriously difficult to read. Mettler-Toledo introduced the technology at Pack Expo 2016.

Metter Toledo’s visual inspection systems come with adjustable user permissions to help prevent system overrides from happening—and if they still do, user tracking in the control software will show managers who was responsible for the override. In addition, Metter Toledo’s systems can be programmed to check all aspects of a label, from ensuring it’s the correct label to verifying the readability of its information. By requiring operators to enter lot codes multiple times—or even requiring two separate operators to enter new lot codes—manufacturers are able to ensure that the correct lot codes have been registered, ensuring traceability. Vision inspection systems will also catch more subtle errors in label presentation, such as improperly spelled or illegible words, unreadable bar codes, and poor-quality graphics.

High-tech solutions

The severity of failing to disclose allergens is extreme because it could result in illness or even death, says Jill Carte, food safety category manager for Bowling Green, Ohio-based DayMark Safety Systems. During the Food Safety Summit May 8-11 in Rosemont, Illinois, Carte says, one top national grocery retailer cited nondisclosure of allergens as one of their top three reasons for product recall of prepared foods and product received from outside manufacturers.

“Undeclared allergens are certainly a problem, however ‘mislabeling’ comes in many forms,” Carte says. “Other reasons for product recall in the allergen arena include cross-contact in preparation, product that is labeled incorrectly and product that is not labeled at all.”

DayMark is working with food software specialist Nutritics on a cloud-based system that helps companies build and manage menu data, Carte says. The system also allows users to automatically identify recipes that contain any of the FDA’s eight major food allergens, and it instantly generates FDA-compliant nutritional data that can be published on a printed label or digital menu for consumer awareness and education.

It's also important, Carte says, for operators to realize that mislabeling can occur along any point in the supply chain, and to work with vendor partners who are up to speed on food allergen labeling and other food safety requirements.

According to the FDA’s Reportable Food Registry, reports of undeclared food allergens increased from 30 to 47 percent between 2009 and 2013, says Hilary Thesmar, chief food and product Safety officer and senior vice president of food safety programs for the Food Marketing Institute. To help reverse the financial impacts of mislabeling on its member companies, the FMI Foundation supports research to help find the causes of mislabeling.

The foundation recently gave a $20,000 grant to the Food Allergy Research and Resource Program at the University of Nebraska-Lincoln’s Food Science and Technology Department for research that will help identify the root causes of labeling errors and recommend best practices for manufacturers, suppliers and retailers in order to reduce undeclared allergen recalls. Findings will be presented at the SQF Institute International Conference in November.

“Failure to adequately control and label allergens will result in a recall,” Thesmar says. “Legal fees, food waste and loss of consumer confidence can be detrimental for food brands vying for increased market share.  Accurate labeling to protect customers is one step that companies have control over in food safety. It takes work, but customer health is depending on accurate information on the labels.”

The difference between product that’s packed and labeled before it comes to the instore deli or bakery and product that’s packed and labeled in-house can be big, says Lynn Dyer, president of the Foodservice Packaging Institute.

The chances of a labeling error occurring are higher when it’s done in-house, she says. The problem is, the demand for customized products is soaring, which means greater variations in ingredients — and, as a result, the need for customized labeling —at the store level.

“From our standpoint, the packaging may not change, but what’s inside might,” Dyer says. “The question is: can technology keep up with the demand for personalized product?” 

Passage of the Food Allergen Labeling and Consumer Protection Act in 2006 dramatically increased awareness of the importance of proper labeling of food products, says Steve Armstrong, a consultant with Alexandria, Virginia-based EAS Consulting Group LLC, which specializes in United States Food and Drug Administration (FDA) regulatory matters. The law requires all food labels in the U.S. to list ingredients that may cause allergic reactions.

“The big challenge is to manage your ingredients so there’s no cross contamination and you’re aware of what’s going into your foods,” Armstrong says, adding that environmental testing is also increasingly becoming a key component for food processors.

The Food Safety Modernization Act also has forced retailers and suppliers to step up their food safety game when it comes to allergan labeling and other issues, Armstrong says. “It’s critical to have a sound and transparent management program, especially since FSMA became law, he says.