Governmental regulations, such as the Food Safety Modernization Act (FSMA), have drastically impacted how food producers perform allergen control. Activities that were formerly merely suggestions are now compulsory in order to minimize the risk of allergens in food products.
Food allergen preventive controls are both essential and beneficial to your bottom line. With increased allergen awareness among consumers, restaurants and other food handlers should encourage employees to train to increase their food allergy awareness and reduce the possibility of incident in their facility.
FDA-Recognized food allergens
The majority of food allergic reactions in the United States stem from 8 allergenic categories. While some of these categories need to be further specified, the inclusion of any of these allergens must be documented to comply with regulations. Under the Food Allergen Labeling and Consumer Protection Act (FALCPA) the FDA recognizes the following food allergens in the US:
- Tree Nuts (species specific)
- Fish (species specific)
- Crustacean Shellfish (species specific)
- Sesame - With the signing of the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act of 2021 into law, sesame will become the 9th major food allergen in the US as of January 1, 2023 Manufacturers will need to reassess their ingredient and process hazard analysis to identify and control the presence of sesame addressing any potential areas of cross contamination, relabel any products with sesame to comply with the new regulation, and retrain employees on allergen control programs and procedures prior to the compliance date.
If your facility uses any of these products in your manufacturing, you must be vigilant in how you handle and manage not only the allergens, but also any materials that might come in contact with them. In larger facilities, consider separating production lines in close proximity with walls, curtains, or partitions to minimize the risk of allergen cross-contact. Additionally, create a hygiene map to indicate where different allergens are stored or located. This also illustrates the flow of allergens throughout the facility, offering a visual representation of any places where cross-contact may occur.
Allergen training and control
Food safety allergen training can inform employees of best practices and also create protocols for your facility. To increase awareness, staff training can include allergen identification and assess the ability of employees to clearly segregate the allergens. Establish a consistent manner to identify allergens within your production. One possibility for allergen identification is using a color-coding system to designate which allergen is present. Alternatively, you can use icons as labels—this prevents risk of confusion for any employees that might be color-blind. Identify allergens on raw material labels using the common name. Some ingredient names do not adequately identify the allergenic material, for example lecithin, which may contain a soy allergen. By listing the common allergenic name, you reduce the chance of misperception for other employees in the facility. When cataloging allergens, also include any packaging, processing aids, colors, flavorings, or lubricants that may transfer to food products.
Allergen controls: prerequisite programs
Allergen controls begin as soon as you receive any materials. Prerequisite programs can be put in place that outline how to treat these materials, including documented allergen checks as you receive them. If your facility takes test samples upon receipt, ensure that you do not use same knives to open bags or containers of unlike allergens. After you do take any samples, ensure proper closure of the bags. Use designated tools and equipment to handle any allergenic materials and prevent cross-contamination.
Allergen controls: storage
When considering product manufacture and storage, be sure to adequately clean any shared equipment. Equipment design can facilitate cleaning, simply by having a sanitary design. Scheduling and engineering controls can minimize the frequency of intensive cleaning. Schedule equipment use in an order that runs unique allergens toward the end to help minimize changeovers. Do keep in mind that robust sanitation protocols must be executed if an allergen is present in one product but is not present in the next product scheduled to run. Visible inspection is one way to verify that the equipment is clean, but some allergens require further testing. If any residue is present, including films or protein sheen, the equipment is not "visually clean." Visible cleanliness is only used as a minimum standard. Validated allergen-specific test kits are available for some food allergens. They detect the presence of food allergens on food-contact surfaces using swabs and are sensitive enough to detect levels of allergens that could cause a reaction.
Storing product causes additional allergen concerns. Keep allergen-containing rework and work in progress in sturdy containers with secure covers and disposable interior liners where this is appropriate. If possible, use containers that do not require equipment to move them—this minimizes the risk of damage to the container, resulting in a possible incident of product mixing with an allergen-containing product. When you do reuse a container, be sure to thoroughly wash and sanitize the container before you reuse it. Any bins used for storage should be marked with information such as the name of the rework, the allergen included, and dates for manufacture, storage, and using the rework. Clearly labeling the allergen and material in the containers helps reduce the risk of accidental product mixing.
Ultimately, allergen control is in the hands of your personnel. Manage employees' outer clothing, as it may accumulate residual allergen from the processing area. Control traffic patterns of both people and raw materials to further reduce risk. Most importantly, proper allergen control training is essential for food companies. Providing food allergy awareness courses is beneficial but emphasizing the importance of food allergen preventive controls is vital to protecting your customers. The Food Safety Modernization Act (FSMA) includes allergen control practices that are necessary for consumer protection and serve your best interests as well. Zosi is an industry leader in online food safety training. Click here to take PCQI training at your own pace. Protect your customers and protect yourself with food allergen preventive controls.