A spoken guidance video explaining FDA food allergen labeling requirements (Federal Food, Drug and Cosmetic Act) and practical manufacturing controls to prevent cross-contact with the top nine food allergens. Covers how allergens must be declared on labels (ingredient list or separate 'contains' statement), specific naming for tree nuts/fish/shellfish, advisory statements (may contain) as voluntary, and recommended allergen control plan elements: team formation, process flowcharting, supplier controls, storage, scheduling, dedicated equipment, sanitation, and employee training.
Chapters
Now, to help protect consumers, the FDA has regulations in place that require food manufacturers to list all ingredients on packaged foods and beverages. These laws are identified in the food allergen labeling requirements of the Federal Food, Drug and Cosmetic Act. There are also more specific labeling requirements for items containing or processed in facilities that use any of the top nine food allergens. The FDA also conducts inspections and sampling to make sure that foods are properly labeled for food allergens and to make sure facilities have controls in place to prevent cross contamination. The law requires food manufacturing facilities to clearly label the food source of all major food allergens used to make that food. This can be done in the ingredient list if the common name of the ingredient includes the allergen, like buttermilk, or in a separate area of the label, clearly identifying all included allergens. The FDA also requires that for tree, nut, fish and shellfish allergens, the specific types identified, e.g. almonds, cod and lobster are specific tree nuts, fish and shellfish that might be found in food products. The allergen's food source must be identified at least once on a food label. This can be done using parentheses in the ingredients list. So, for example, the ingredients might say flour with the allergen of wheat identified in parentheses. This requirement can also be met by using a contains statement in which all of the included food allergens are going to be listed. Allergen labeling requirements include all retail and food service establishments that package, label or offer products to consumers to eat. You might also see some food packages that say phrases like may contain or produced in a facility that uses, followed by the name of that allergen. These advisory statements aren't required by law, but they can be used by facilities with to address any unavoidable cross contamination issues that might arise. Manufacturers should always follow good manufacturing practices in their facilities and then take every precaution to avoid all cross contamination. It's also recommended that food manufacturing facilities create an allergen control plan. This is a written document that a company creates and keeps on hand that defines processes in the handling, processing, packaging and identification of allergenic foods and ingredients. Allergen control plans should be updated anytime there's a change in process or supplier and new employees have got to be trained appropriately. The first steps to identify key team members from each department to then participate in the planned development. These can include manufacturing, quality control, labeling, compliance, research and development, engineering, sanitation, and of course, food safety. Team members should then create an allergen process flowchart to help determine where allergenic Ingredients exist in the facility and where they're introduced in the process. The team should also decide if the allergenic ingredients actually needed in the product. Allergens that have no or minimal functional effect in the finished product should be excluded were substituted. When receiving ingredients from suppliers. Steps should be taken to identify and label allergens immediately before the possibility of cross contamination. First, you review the labels of all incoming ingredients for appropriate allergen info. Any raw materials containing allergens should be tagged and separated. Allergenic ingredients should be stored separately in clean sealed containers whenever possible. Now, if separate storage isn't feasible, like allergens should be stored together like peanuts and tree nuts, right? And these allergens shouldn't be stored in areas where they can then leak into non allergenic materials. It's also recommended that manufacturing facilities require suppliers to alert them if there's been a change in the ingredients that they're supplying during the manufacturing process. It's best practice to schedule long runs of products containing allergens to minimize the possibility of cross contamination. For example, if some of your cookies contain peanuts and others don't produce, all of those that don't contain peanuts first, followed then by all the peanut cookies. When possible, produce allergenic and non allergenic items in separate areas of the plant using designated machinery. Also, if possible, physical barriers should be constructed right between the areas and the sharing of employees. Packaging supplies and raw materials should be limited. Any dedicated tools and equipment that's used in the production of foods containing allergens have got to be clearly marked using a color coding or some other easily visible system. Sanitation protocols should be initiated immediately following the production of any food containing allergens. Leftover allergen residue can easily make its way into the next product being made, which leads to cross contamination and potentially fatal effects. Sanitation protocols should be defined and written in the allergen control plan and include who's responsible for cleaning operations, what products are to be used, and the procedures for thorough cleaning. Training on these procedures also needs to occur frequently. General training on allergen awareness and control should be provided to all employees. Now, while there is no legal requirement under the FDA when it comes to allergen cross contamination, following these recommendations can help keep consumers safe and avoid food contamination.
