For those of us who follow food safety on a day-to-day basis, allergen-based recalls are easily recognizable as the most common source of major recall events (although pathogen recalls are a relatively close second). Whether you yourself suffer from food based allergic reaction, or just know others who are susceptible, it is a daily issue that touches just about every American. A little bit of food safety trivia - allergens are treated as a chemical risk in food, not biological.
In my HACCP post, I used the analogy of home security as a way of thinking about food safety programs, and in furthering that analogy we can see how allergens can be very tricky to manage from a safety perspective. When we think of pathogens, it is easy to classify them as intruders in all scenarios. For allergens, we can think of dangerous objects inside of the home, think of the electricity, the oven or other appliances. They are inside the system and used regularly, but can cause devastating injury when mishandled. It’s one thing to determine how to keep problems out, but it can be much harder to keep track of the dangers already present, and so it is with allergens.
Even though most people are aware of milk allergies or peanut allergies, they are unaware of what the official allergens are in food or how they are regulated. Allergens are actually a relatively new regulatory issue, certainly much newer than HACCP based food safety and newer than the big pathogens. Starting in 2008 (the rules were passed a few years before that), the government regulated which food allergens must be declared on a label, and how that process would be enforced for businesses. For the record, in America, the official allergens are: Milk, Eggs, Fish, Shellfish, Soy, Wheat, Peanuts and Tree Nuts, referred to as the “Big 8.” As such, they must be declared if they are present in a packaged food, and they must not be detectable beyond a few parts per million (mg/kg) if they are not supposed to be in the food.
Anaphylactic shock is a deeply traumatic thing to go through, and almost equally traumatic to observe. That food is one of the most likely causes of anaphylaxis adds to the already high degree of danger inherent in food. Unlike pathogens, proteins that cause allergic reaction do not live or grow in food, but are inherent to the ingredients used in production of our food. That makes it much easier to control than E. coli, Salmonella, Listeria, Staphylococcus, Campylobacter or Clostridium botulinum.
So if allergens are much easier to manage, why are they so much more likely to cause problems in supply chains? The reason, unfortunately, is human error. There are three main sources of human error caused allergen recalls - mislabeling, cross contamination and using the wrong ingredients during manufacturing. When reading a recall notice, it can be difficult to determine if the ingredient was supposed to be in the food and was just not included, or if it was mistakenly put into the food. This is very common with baked goods and chocolates, which regularly have nuts, wheat and milk as possible ingredients.
As companies develop and produce packaged goods, artwork for products that make it to the grocery store is difficult to manage. Foods with short shelf lives or that are popular seasonally are very susceptible to rush design of labels, and as anyone in the marketing world can attest to, copy editing of artwork is easy to mess up. Last minute changes, miscommunications or just plain errors happen all the time. If a manufacturer is using allergens and doesn’t notice that a product has an allergen, it may just be omitted from the declaration, even if it is in the ingredient statement.
More common is the mistaken usage of ingredients during production. I purchase an ingredient from a supplier and the sales rep says he’s pretty sure that it is egg free. The production line is set up, no one checks the label of the ingredient carefully, and you accidentally have egg in the food.
In a different scenario, an employee in the warehouse goes to pull pallets of one kind of flour and instead pulls a different flour with a very similar looking bag. Again, this is not caught during production.
Lastly, putting on the wrong label can cause an allergen recall if the incorrect label lists the wrong allergens or fails to list the allergen in the product. Sadly, this is a regular occurrence (observable a week before this writing in salad dressing).
As often as not, allergen contamination is discovered by customers complaining to the food manufacturer, or to the government regulator that they ate something that caused a reaction. The companies involved often are completely unaware that they have made the error, especially in facilities that do not have regular inventory reviews (this is how mistaken ingredient use is often discovered).
In the next article, I’ll get into how companies go about preventing allergen contamination in food.