Putting a Face to the Risk

Natalie. At 13 years of age, Natalie died in her father’s arms after taking a bite of a Rice Krispies treat that was iced with chocolate and peanut butter — even after immediately spitting out the treat when she tasted peanuts and having her parents administer multiple doses of Benadryl and epinephrine.

Sabrina. Sabrina’s final meal was a high school cafeteria lunch to which she had an anaphylactic reaction and died. The peanut- and dairy-allergic eighth-grader ordered fries after making sure that they were cooked in vegetable rather than peanut oil. But it wasn’t an inadvertent oil that killed her, it was cross contact from tongs used to lift her fries that were also used on cheese-covered fries.

Landon. At 11, Landon died of anaphylactic shock after eating a cookie from a grocery store which was not marked as containing peanuts and which a store associate had told his mom contained no tree nut allergens.

THE RISK IS REAL. Natalie, Sabrina, and Landon are real people. No names or facts have been changed. Worse, they are just three of the 177 accounts of deaths of food-allergic children and adults caused by unlabeled allergens or cross contact since 1986 (as compiled by No Nuts Moms Group).  

And they are just three of the incidents which North Carolina State College of Agriculture and Life Science Extension Associate Natalie Seymour describes to put a human face to the potential consequences of allergenic contamination in her allergen risk management educational presentations.

“Food safety comes down to people,” Seymour said. “But the people factor provides a lot of variability, not just between people, but also day-to-day. So how do we help these people understand why allergen management is so important and get it right every time?”

Providing the answer to her own question, Seymour said that food facility workers need to be educated not only on what they should do but on why they need to do it. “Your food will be only as safe as your most unsafe practice,” Seymour said. Additionally, it is important to ensure against an environment of bystander apathy, in which everyone is of the thinking that: “Someone else will do it”; “There’s nothing I can do”; or “What I do doesn’t matter.”

Thus, it is critical that workers understand the risks involved with allergen control; that allergies are real and can be severe and life threatening; and what they can do to help manage risk. “I am a firm believer in trusting the intelligence of people you’re working with and giving them the why,” she said.

Seymour provided a simple three-step solution to allergen risk management education on the why and the how:

1. Tell stories.
2. Find problem areas.
3. Present simple solutions.

1. TELL STORIES. In her presentations, for example, Seymour tells Landon’s story: the 11-year-old, who had a life-threatening tree nut allergy, was at the grocery store with his mother when he saw the cookies in the bakery counter window. His mom checked the labels and saw no indication of nuts in the cookies; as further clarification, she asked the clerk if the cookies had nuts. When told no, she bought a cookie for Landon — tasting it herself, first, as a final precaution. But when Landon took a few bites of the cookie, his mouth began to burn in reaction to what was later found to be walnuts in the treat. He was given Benadryl and epinephrine, but Landon fell unconscious, his throat swelled, and doctors were unable to resuscitate him.

Telling food workers that allergen labeling is important is one thing. Imparting a story of the real impacts of unlabeled allergens, whether caused by mislabeling, inadvertent cross-contact, or lack of sanitation, goes to the heart of the why — and the hearts of the workers. Landon’s story will be remembered long after simple statements of “Check the labels at changeover” or “Be sure you clean the line well between runs.”

Why? Because a person can die.

In fact, Seymour said, “A lot of the deaths we are seeing are the result of very simple actions.” Using a utensil on a non-allergenic food that was used on an allergenic food without being cleaned can cause a death — such as that of Sabrina (at the beginning of this article). “Just a trace amount on a utensil was enough to cause her reaction,” Seymour said. Children die because people make avoidable mistakes — cutting corners or not cleaning properly. And it doesn’t matter if that mistake is in the school cafeteria, a restaurant, a food-production facility, or anywhere else along the food chain. A trace amount of an allergen in a food consumed by a food-allergic person can cause a severe reaction or lead to death.

In her training, Seymour also has used docudramatic videos of life-threatening allergic reactions, such as that produced by Face Your Risk (https://youtu.be/HX4yBmuazqM). “Having employees see that can be very powerful and stick with them,” Seymour said. When viewers sometimes say, “I don’t want to see that; it’s uncomfortable,” she responds, “Would you rather see it in a dramatization or for real?”

2. FIND PROBLEM AREAS. Just as areas of employee movement between raw and cooked foods can be food safety hazards, so too can movement between allergenic food production, ingredients, or final products with non-allergenic foods be a hazard. For example, Seymour said, a worker moving from an area of peanut-containing food production could track peanut dust into a non-nut area, which could get into the air and on food.

While a food facility may have standards along these lines, the simple act of an employee switching jobs to “help out” on a short-handed allergen-free production line could cause cross contact and impact consumer health.

In the same way, equipment or utensils brought from allergenic to non-allergenic areas without being completely cleaned and sanitized, can cross contaminate foods and cause a food allergy reaction in a consumer.

Because every food facility is different, produces different foods, and follows different practices, you will want to conduct an assessment of your own operations, how allergens are handled and managed, and what practices could be compromising the safety of your foods and its consumers.

However, there are some areas that are fairly consistent across the industry, and some simple solutions that can be implemented in facilities that produce both allergenic and non-allergenic foods, focused primarily on storage, preparation, and production along with personal hygiene and contamination.

3. PRESENT SIMPLE SOLUTIONS. In addition to understanding why they are doing something, employees need to know how it is to be done. You can simply tell workers to be sure the line is clean without explaining your sanitation process and requirements. But, Seymour said, “If I tell someone why but not how, they will wonder, ‘What do I do about it?’ So the best types of training not only give reasons why but also how.”

There are a number of risk management techniques that are very simple to implement. For example, Seymour said that color coding is a great way to help people understand what is to be used in specific areas. “People recognize color faster than words, and color has no language barrier,” she said.

Because it is possible that you have workers in the plant who are color-blind, the best practice would be to have color and a label or differentiating patterns. “The bottom line is helping people to make visual connections,” she said. When coupled with training, it provides a standing reminder.

Other simple solutions:

• Store allergenic and non-allergenic ingredients and supplies in separate areas, with proper labeling. Maintain a clear and consistent protocol for labeling.
• If at all possible, have dedicated equipment that is clearly labeled and used only for allergens, including transportation equipment such as dollies.
• Have as much separation as possible between allergenic/non-allergenic foods and production — in both physical space and time, with completely separate areas if possible.
• Best practice is to dedicate employees to allergenic and non-allergenic areas. If this is not possible, employees should change clothes and wash hands before entering an allergen-free production area.
• When allergenic and non-allergenic foods are run on the same line, run non-allergenic products first, following the sanitation shift. Then run allergenic foods, and clean and sanitize again.

It all comes down to helping employees understand that what they do really matters. Because they don’t see the people eating the foods they are a part of producing, it can be too easy for workers to disassociate themselves from the fact that it is consumed and can have health impacts. And because addressing any one area can help improve others, implementing three simple steps for food allergen risk management can have significant impact on your food safety as a whole.

The author is Editor of QA and can be reached at llupo@gie.net.