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Steps to Prevent Allergen Recalls – A Practice Tip from Ms. Gloom

Anyone who is remotely involved in the food arena knows that the number one reason for a recall of meat and poultry regulated under USDA’s Food Safety and Inspection Service (FSIS) or all other types of food regulated under the Food and Drug Administration (FDA) is an undeclared allergen.  In fact, a quick review of recalls in Canada shows that undeclared allergens probably result in most of their recalls as well.

So what is happening in food facilities that result in all of these products being manufactured or labeled improperly?  What can be done to control the process and prevent the risk to the consumers who depend on the product label to provide the correct ingredient statement – besides all of the regulatory oversight that will occur at the facility once you have a recall?  There are several procedures that facilities can implement to ensure products are not only produced, but also labeled, correctly.

Many facilities say that they control allergens by having a critical control point (CCP) at packaging to ensure that the finished product is correctly labeled.  For example, someone checks that a hotdog package or package of hotdog buns has the right label on it as part of a CCP at packaging.  The “right” label is determined because the schedule indicates that beef hotdgs were being made or white buns were to be packaged.  The problem with this approach is that while someone can determine that beef hotdogs were made or that a regular white bun was used and the label reflects this fact, the person visually checking the product and label won’t know whether someone used the wrong spice blend in the product.  The person would not know that soy oil was added to the bun instead of a different type of oil because the manufacturer changed sources of oil without notifying the establishment.  While it is important to ensure that the correct label is going on at the end of the line, the real work starts at receiving!

Receiving Ingredients

Anyone who has reviewed ingredient statements for products with numerous ingredients knows how difficult it is to compare two statements which are the virtually the same – except one is missing an ingredient or two, or the statements have the same ingredients but not in the same order of predominance.  Now, try to do this while efficiently unloading 22 pallets of various ingredients from a trailer as is the procedure at many facilities.  Even when there are several personnel involved in the receiving process, this becomes a difficult task.

In reviewing the lessons learned through recalls, many recalls resulted from the ingredient supplier changing the formula of, for example, a spice blend or a complex sauce and neglecting to notify all of their customers beforehand – or the notification occurred but did not reach the receiving dock. This should always be a concern when trying to compare the incoming ingredient label with the ingredient statement in your spec book while keeping up with the unloading of materials.

A tip to prevent a gloomy day: if you receive multi-component ingredients, you can make it easy for your employees at receiving to quickly identify whether or not the incoming item has the same ingredient statement as that approved – and which is used on the respective finished product label: use transparencies.


If you are old enough, you may remember that before we had computers and Power Point presentations, we had transparencies.  These were clear plastic sheets we could run through the copier and print our presentations or pictures on to, which we then displayed onto a screen with an overhead projector.  These clear plastic sheets can still be run though the copier and printed with “life size” copies of your suppliers’ ingredients statements.

Get an actual ingredient label from all of your incoming ingredients which you have verified as correct.  Take each of these and make a “transparency.”  Provide these to your incoming receiving personnel.  These transparencies can then be used by these personnel to quickly place over the respective incoming ingredients statement to determine whether or not there has been a change.  If the label on the transparency perfectly “matches up,” then there has been no change and product is good to receive.  If it does not match up, something has changed and the receiver can take appropriate next steps.

The use of transparencies will greatly speed up the process of ensuring ingredients received are correct with much greater accuracy than trying to actually compare two statements side-by-side.  Transparencies will not “catch” an issue where the supplier formulated a product incorrectly; they will, however, prevent those issues where the formulation and label were changed and the facility was not made aware of the change – an issue which has accounted for numerous allergen recalls.

My next blog will address some steps to take to try to ensure you are formulating, batching, and labeling your products correctly.

About “Ms. Gloom”

In the attorney ranks at OFW Law, there is only one who would raise a hand if all were asked if they had any “hands-on” experience in the operation of a Townsend “Frank-O-Matic” hotdog maker, producing bean sprouts for use in egg rolls or in managing a food facility sanitation crew.  In fact, there are probably no attorneys out there who could raise their hands except Jolyda Swaim.

Prior to law school and OFW Law, Ms. Swaim spent years in the food industry, beginning as a microbiologist and Quality Assurance technician.  In these years, she had direct charge of quality assurance, production, sanitation and consumer affair departments at various companies producing products from pickles, sauerkraut and barbeque sauce, to various meat and poultry products, to frozen entrees, egg rolls and pizza to spices and spice blends.  Her last position at Sara Lee as Director of Food Safety had her auditing its facilities in the United States and Mexico to ensure facilities producing ready-to-eat products were following best practices in sanitation and product handling.

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