Allergen Cross Contact

Features - Safety

Challenges and Recommendations Involve Entire Supply Chain.

October 1, 2014

Allergen management is a critical component of any food safety program and is becoming even more imminent with the pending rules of the Food Safety Modernization Act (FSMA). To discuss allergen management in relation to the challenges food processors face, along with the use of color-coded tools and other recommendations for prevention, QA spoke with Nelson Jameson Technical Director Fritz Buss, Detectapro Marketing Manager Paul Gaertner, and Hill Brush Marketing Administrator Nicola Rydlewski. Following are their responses to four key questions.

1. What are some of the challenges that food/beverage processors face in the prevention of allergenic cross contact? 

Gaertner: The greatest challenge that food and beverage processors face in the prevention of allergenic cross contact is that of the employees themselves. Employees have to become more diligent in operating within the parameters set by the company. Training plays a big part of this, but training alone can’t keep it from happening. Employees must take training to heart and realize everything they do on the floor could have an allergenic consequence elsewhere in the plant.

Buss: The first challenge is identifying the allergens—especially the “big eight” or proteins derived from them (see list above)—that are present in their facilities and putting in preventive controls to prevent cross contamination by these. This requires the involvement of suppliers and an audit of their allergen control programs.

Rydlewski: With ever-increasing emphasis being placed on the importance of cleanliness and preventing product contamination, the food and beverage industry is under constant pressure to comply with stringent standards of hygiene. Consequently, management personnel need to be able to demonstrate due diligence.

2. How do color-coded tools aid in this prevention? 

The Big 8

More than 160 foods can cause allergic reactions in people with food allergies, but the “Big 8” account for 90% of food-allergic reactions. The eight foods, and any ingredient that contains protein derived from them, that are designated as major food allergens and require allergenic labeling are:
  • Milk
  • Eggs
  • Fish (e.g., bass, flounder, cod)
  • Crustacean shellfish (e.g., crab, lobster, shrimp)
  • Tree nuts (e.g., almonds, walnuts, pecans)
  • Peanuts
  • Wheat
  • Soybeans

Gaertner: Color-coded tools (e.g., pens and cable ties) are coded for a reason. It keeps the product in the area. For example, a facility that produces products with nuts stipulates that the red body pen stays in the nut area. If that pen travels to the non-nut producing area, it could carry an allergen that could have deadly consequence to an end user.

Buss: A key to preventing cross contamination is isolation from other ingredients and non-allergen-containing finished products. Once trained, employees will segregate and properly store containers and utensils according to colors representing the various allergens.

Rydlewski: Correct storage of cleaning tools is paramount in controlling the spread of allergens and preventing contamination. Implementing color-coded hanging systems which coincide with the color of the cleaning tools for each area is a vital part of a company’s hazard analysis and preventive control scheme. If tools are cleaned thoroughly and stored away from surfaces which could cause contamination, it will limit the risk of cross-contact.

3. What other recommendations would you have for prevention?

Gaertner: Organizations should use products that help in the reduction of allergenic cross contamination whenever and wherever possible. And, as always, have employees that buy into that way of thinking. Ultimately it ends with the employees and their commitment.

Buss: Supplier integrity in meeting specifications, employee discipline in following the segregation program based on color coding, and effective sanitation are key to preventing cross contamination of allergens. This is where the phrase “Trust but verify” is highly applicable. Another might be “What gets measured gets done.” Test kits are available which will check raw materials and ingredients for traces of allergens. There are a variety of sanitation verification tools which may be used both pre-start-up and during “down-time” inspections of food-contact surfaces, including storage containers and utensils. Pre-start-up tools are typically less sensitive but will quickly detect allergens in amounts most likely to cause a problem. These include a high-intensity LED-type flashlight for visual inspection, protein swabs for food contact-cleaning verification which indicate contamination based on a rapid color change, and allergen-specific as well as broad-spectrum test kits that are validated for a wide range of allergenic proteins. Down-time detection swab kits, based on color change following incubation or ELISA reactions, are usually highly sensitive and verify that little, or virtually no, residue remains on surfaces. These would be used to ensure that the allergen management SSOPs are effective, especially for hard-to-reach food-contact surfaces.

Rydlewski: A recent study into the prevention of meat cross-over showed the risk was vastly reduced when meat-processing equipment was cleaned between breeds. This may seem to be an obvious finding, but it is critical in understanding how to control risk, including that of allergen cross-contact. When food processing plants produce a variety of products, the risk of cross-contact is far greater. To limit the risk and adhere to preventive procedures, processors are required to list known allergens and ensure these items are clearly labeled. With an array of factors contributing to cross-contact, including people, cleaning, storage, packaging and transport, having the appropriate risk assessment in place for all stages of production is vital.

4. What final thoughts would you have for processors?

Gaertner: Processors should use metal- and x-ray-detectable tools wherever possible, and use color-coded and antimicrobial tools where needed. The main goal is to reduce contamination, be it through allergens or other objects. The safety of the end user is the main goal and every company in the processing realm owes the end user the delivery of safe product.

Buss: Keep up to date on FSIS guidelines for allergen control and FDA FSMA requirements, which will impact upstream/downstream cooperation throughout the supply chain. It is extremely important to include distribution, transportation, and warehousing—which often are the weakest links, and to review supplier allergen control measures and recall plans at all levels of the supply chain. Stay active in trade associations; consult with suppliers and distributors and other resources that can provide information and training related to allergen-control measures.

Rydlewski: The ever-present risk of cross contact must be controlled through the use of work-area segregation, suitable storage of ingredients, and appropriate cleaning, be this wet, dry, or CIP. Stubborn residue must be removed from hard-to-reach areas, such as the inside of intricate pipework. To safeguard consumers, wearing appropriate protective equipment, such as aprons, hair nets, and shoe covers also will assist in allergen control.


New UK Allergen Labeling Rule Effective December 13

Beginning December 13, 2014, new allergen labeling regulations will apply to all pre-packed foods sold in the United Kingdom. The new rules, which were published in October 2011, will be enforced by the Food Information Regulations 2014.

Under the new rule:

  • Manufacturers must declare the 14 major allergens of the EU, including cereals containing gluten; crustaceans (e.g., prawns, crabs, lobster, crayfish); eggs; fish; peanuts; soybeans; milk; nuts (e.g., almonds, hazelnuts, walnuts, pecan nuts, Brazil nuts, pistachio, cashew, macadamia nuts); celery (and celeriac); mustard; sesame; sulphur dioxide (a preservative in some dried fruits); lupin; and mollusks (e.g., clams, mussels, whelks, oysters, snails, squid).
  • Allergens are to be declared and emphasized within the ingredients list. Manufacturers can choose the method of emphasis, including bold, contrasting colors, or underline.
  • Allergens should be declared with clear reference to the name of the allergenic ingredient; if several ingredients or processing aids come from a single allergen, the labeling should clearly emphasize each ingredient or processing aid.
  • The voluntary use of “Contains” is no longer allowed. All information about allergenic ingredients must be in the ingredients list.
  • However, an allergy advice statement on the product label to explain how allergens are emphasized within the ingredients list is allowed (e.g., Allergy Advice: for allergens, see ingredients in bold).
  • If a food does not have an ingredients list (e.g., wine), statements such as “Contains: sulphites” can be used as applicable.
  • Precautionary allergen labeling should be used only when a thorough risk assessment has been conducted, and a real risk of allergen cross-contact exists that cannot be eliminated. When this is the case, the label may include one of the following:
    • May contain [allergen].
    • Not suitable for someone with [allergen] allergy.