Comprehensive Allergen Management

As detailed in “My Story” (page 46), accidental consumption of a food to which a person is allergic can have severe consequences for that person — and ultimately for the company which produced the food if it was mislabeled or cross contaminated in the manufacturing facility. This article discusses the prevention of cross contact of allergenic and non-allergenic foods, recommended training, and the impacts of COVID-19.

“A thorough allergen control plan makes decision-making easy and leads to fewer allergen accidents,” said Emport LLC President Emily Kaufman. Dedicate the time and expend the resources to create a comprehensive allergen control plan, and, Kaufman said, “Review that plan any time there are changes in your ingredients, suppliers, staff, equipment, or products.”

The plan should include clear answers to day-to-day decisions such as, “Which shelf do I put this ingredient on?” and “Which set of tools do I use for ingredients with this vs. that allergen.” Strategic product formulation to avoid allergenic ingredients as much as possible also can help in limiting the potential for cross contact. The fewer allergens in your facility, the fewer your opportunities for cross-contact, Kaufman said. In product development, questions should be asked, such as “Is that allergenic ingredient truly necessary?” and “Is there a cost-effective, functional and flavorful allergen-free alternative?” 

Where allergenic ingredients are used, they should be physically separated and run on different production lines and/or during different shifts with validated cleaning procedures between production runs, said Bia Diagnostics Laboratory Manager Luke Emerson.

With a goal to minimize cross-contact between allergenic and non-allergenic foods — and business risk, a food manufacturing facility’s allergen control plan should be robust, said 3M Food Safety Global Technical Service Specialist and Microbiologist Gabriela Lopez-Velasco. The plan should include:

Segregation of allergenic foods in warehouse storage. “Mindful of available space, food companies must maintain physical separation between raw materials or ingredients that contain food allergens and those that do not contain them,” she said. Along with clean, dedicated containers for allergenic ingredients, this could include separate warehouses, or it could be separate locations in the same warehouse. It also is good practice to store allergens on the lowest shelf so they cannot contaminate ingredients below if product spills.

Transportation (from supplier site or warehouse to plant). Consider which ingredients should or should not be transported together, or if physical barriers such as pallet covers could be added.

Allergen cleaning. “Operationally, food processors must remove the physical residues of previous food product so that the next product to be manufactured is not contaminated,” she said. Cleaning operations should be validated using effective technologies to demonstrate that the procedure is capable of removing the allergenic food from equipment. Once validated, maintain routine verification to monitor its efficacy. “Allergen cleaning and sanitation should be scheduled right after the production of any foods containing allergenic ingredients,” Lopez-Velasco added.

Packaging. “Packaging errors make up an embarrassingly large portion of allergen recalls across the globe,” Kaufman said. “These recalls are cheap to prevent, but they still fall through the cracks.” At the end of a production run, a check should be conducted to ensure that the product matches the packaging. This can be as easy as opening a package: If the box says “chocolate chip cookies” but contains peanut butter cookies, it’s time to pump the brakes, she said. When products look similar, a rapid allergen test can provide reassurance or early warning. 

TRAINING. “Communication and training are the base of any successful food safety plan,” said Lopez-Velasco. Training that is specific and appropriate to the worker’s role should be considered before risk management strategies are implemented. All employees should be educated on the impact to allergic consumers when risk management activities are not correctly followed, as well as on the symbols or colors used to designate allergenic ingredients.

“Following a strong allergen control plan very literally saves lives,” Kaufman said. “People do a better job when they understand why they are doing something instead of just how to do it. To that end, education that puts a personal face on food allergy is more effective than training that just ticks off the new rules.” 

Training also should empower all employees to speak up if they see something amiss. They need to know how to report a concern, and that they won’t be reprimanded for “slowing down” the line, she said.

All workers also need to understand the importance of cleaning and how to check that cleaning has been properly conducted, Emerson said, emphasizing the importance of validating cleaning and testing procedures, performing risk assessments to determine the scope of controls necessary, and having well-documented employee training.

COVID-19 IMPACT/AFTEREFFECTS. “The food industry has definitely been impacted by the COVID-19 pandemic,” said Lopez-Velasco. But, she added, “While COVID-19 poses a major risk to the entire human population, it is important to consider that foodborne pathogens, food allergens, and other common physical and chemical risks in foods are still present.”

Now more than ever, maintaining a safe food supply chain and sanitary conditions as well as adhering to food safety plans and good manufacturing practices should be a priority. “Allergen controls are no exception,” she said. “Allergen management activities should remain in full force during this time.” Additionally, during times of challenges, such as that of the pandemic and the gradual recovery of business, recordkeeping and verification of allergen management activities are important to ensure that the food management activities remain effective, despite the changed environment and team members.

“People with COVID-19 who have food allergies might be in greater risk of much more serious infection if they also come in contact with a food they are allergic to at the same time,” said Bia Diagnostics CEO Thomas Grace. “It’s even more important that food manufacturers have strict allergen protocols in place at this time,” he said, as workers may be pressed into service in part of the facility and not know the proper protocol they are tasked with there.

While the challenges of the pandemic and business recovery are causing greater challenges for the food industry, manufacturers need to take care before deciding to cut corners. “It’s always okay to review your food safety vendors — maybe there is a quicker test or an outside lab with better pricing — but allergen management is the wrong area to cut corners,” Kaufman said. “An allergen recall isn’t just expensive and bad for your brand, it can also be deadly.”

The pandemic-triggered supply shortages may also have caused some facilities to source ingredients from new suppliers who, in turn, may be sourcing ingredients from new locations. Thus, Kaufman said, “It’s important to be vigilant about the entire supply chain of every single ingredient.” Ask questions such as: Who delivers the ingredients, and what else do they deliver on the same trucks? Where is the ingredient packed or processed, and what allergens pass through that facility? Where is it grown, and what else is harvested with the same equipment? “Now is a great time for companies to review their supplier agreements to guarantee that they receive timely, written notice of even minor changes in their supply chain,” she said.

“Allergen management should be continuously reviewed and revisited when risk has changed, is changing, or is about to change,” Lopez-Velasco said. “Leaders need to bring their team together and continue assessing risk to make sure that allergen management activities remain effective.”

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