your company’s allergen control plan recall-proof?
A food recall is
a high-impact event that could potentially cripple a company. Apart
from the health risks and exorbitant costs associated with such an incident,
the ensuing brand and reputational damages may be severe and long-lasting.
In spite of a company’s best efforts to produce safe foods that
comply with applicable legislative requirements, errors can occur, production
processes can fail, and controls can falter, meaning that an immediate
recall can become a real and daunting eventuality. Although multiple
factors may lead to recalls in today’s globalised and complex
food supply chains, evidence from several countries suggests that many
more products are recalled due to labelling errors than from any other
cause, including microbial and foreign-object contamination.
did you know…
these labelling errors, undeclared allergens continue to be a
major cause of food recalls in recent times.
the previous decade, the food industry has been hard-pressed to
gain improved knowledge of the impacts of food allergens in the
supply chain and to consumers. This has largely been attributed
to the reported increase in the incidence of food allergies, and
the associated passing of legislation in many countries (including
South Africa) stipulating the declaration of specific ‘common
allergens’ on food product labels.** These ‘common
allergens’ typically include the ‘Big 8’ believed
to cause ca. 90% of food-allergic reactions, namely cow’s
milk, egg, soya, peanuts, tree nuts, fish, shellfish, and gluten-containing
cereals. In accordance with such legislation, failure to indicate
these is both unlawful and potentially hazardous to consumer health,
thus compelling recalls in many cases.
common exactly? Allergen recall statistics are severely
lacking in South Africa; and since government does not maintain
such data or make it publicly available, ‘silent recalls’
are bound to have occurred. With allergen labelling now being
a legal entity, related recalls are expected to increase. This
has already been exemplified by the 2011 Class I recall by General
Mills of a muffin mix that potentially contained undeclared nuts.
is a food recall?
A food recall is any corrective action taken to remove
a product from the market to protect consumers from the potentially
adverse effects of misbranding, contamination or adulteration.
Recalls are often initiated on the manufacturer’s initiative
(voluntary recall), but may also be ordered by statutory authorities
Why are food recalls initiated?
- Product is in violation of applicable regulations
- Legal action could be taken against manufacturer
- Product could lead to health hazard or brand damage
What are the types of food recalls?
Trade/industry recall: recovery of products from distribution
centres, wholesalers, catering institutes or outlets selling food
for immediate consumption.
Consumer recall: extensive recovery of products from
all points of production, distribution and retail, as well as
What are the classes of food recalls?
Class I recall: an emergency situation involving a health
hazard where there is a reasonable probability that ingestion
will cause serious adverse health problems or death.
Class II recall: involves a potential health hazard,
where there is a remote probability that ingestion will cause
a temporary or reversible health problem.
Class III recall: involves a situation in which ingestion
is unlikely to cause a health problem.
the international front, allergen recalls in the US, Canada and
Australia/New Zealand (ANZ) more or less doubled in number between
fiscal years 2007 and 2012 (Fig. 1). During this period, a total
of 732 allergen recalls were recorded by the US Food and Drug
Administration (FDA), of which 63% were Class I and 35% were Class
II recalls. Although recalls have recently been initiated due
to all of the ‘Big 8’, the frequency for some allergens
is higher than for others. Data from the US and ANZ (2007-2012)
indicate that milk has been the chief offender, trailed by wheat,
soya, peanut, tree nuts and egg, while fish has been implicated
to a lesser extent (Fig. 2). US allergen recalls for bakery goods,
snacks and confectioneries have outpaced those for all other food
categories, with the root causes being primarily labelling omissions,
incorrect packaging, unclear terminology, and cross-contact.
international allergen recalls
19 Jan 2014: A Kentucky company, Truitt Brothers Inc., recalled
1.77 million pounds of Kraft Velveeta cheese macaroni products
that contained undeclared hydrolysed soya protein and dried soya
sauce. The root cause appeared to lie with a label supplier who
had mixed product labels listing different allergens.
4 Feb 2014: ConAgra recalled ca. 27 tons of chicken noodle
soup that contained egg and wheat which were not declared on the
label. The company was alerted to the problem via consumer complaints.
26 Feb 2014: Sainsbury’s recalled chestnut, hazelnut
and thyme stuffing mix due to undeclared peanuts.
8 March 2014: Altra Foods Inc. recalled Chocolat Alprose
brand 52% Cacao Premium Dark Chocolate, since the product contained
milk that was not declared on the label.
persistent trends, allergens continued to be the single largest
cause of food recalls in the US in 2013, accounting for a staggering
60% of FDA and 65% of US Department of Agriculture (USDA) recalls
in the second quarter of this year. Undeclared allergens were
also the basis of 35% of food recalls in the UK in 2011, with
prominent supermarket chains such as ASDA, Tesco and Morrisons
being involved in these incidents. Clearly it is not only small
manufacturers, but also the biggest and the best that have struggled
to ensure compliance with prevailing legislation and have fallen
victim to allergen recalls. Such findings serve as a wake-up call
for all members of the food industry to tighten manufacturing
protocols and controls.
a recall-proof allergen control plan
The hazards that give rise to allergen recalls exist in almost
every food-manufacturing facility, but their effects can largely
be mitigated through the implementation of a robust and verifiable
allergen control plan. Risk assessments and applicable operating
procedures form the basis of such a plan, and include –
among other actions – the identification of potentially
allergenic raw materials; the segregation of allergens during
receiving, storage and production; validated cleaning procedures;
and the accurate labelling of products according to legislation.
In addition, the efficacy of these measures should periodically
be substantiated by allergen residue-testing by appropriate analytical
methods (e.g. the Enzyme-Linked ImmunoSorbent Assay [ELISA] or
Polymerase Chain Reaction [PCR]).
with a state-of-the-art control plan, however, a food manufacturer
had best be prepared to take a proactive stance in protecting
individuals – and their brand – with a thorough and
critically-evaluated recall plan. This plan should detail the
step-by-step procedures to be taken from that formidable moment
when undeclared allergens are discovered in consumer-facing products.
The most vital element of a successful recall is timing. The company
needs to respond immediately and complete the process rapidly
to reduce negative public and financial impact; which will only
be made possible through pre-planning, the involvement of the
correct individuals, and clear communication.
effective recall plan should include:
• Key personnel and accountabilities: a recall
team should be pre-determined and the responsibility of each member
should be defined, as should the designation of a recall co-ordinator
• Contact and notification measures: emergency contact lists
and notification procedures should be drawn up to permit communication
with recall team members, authorities, distributors, retailers
• Records: Current and effective traceability records should
be available for tracking where each consignment of effected product
has gone, as well as measures for reconciling the amount recalled
with that distributed.
• Procedures for food retrieval and disposal.
• Review: Post-crisis root-cause analysis, and corrective
actions needed to prevent reoccurrence.
local guidelines to assist with food recalls:
• Department of Health Policy Guidelines: National
Food Safety Alerts and Official Product Recalls in South Africa.
• The Food Safety Initiative Food Industry Recall Guideline,
compiled by the Consumer Goods Council of South Africa.
allergen-labelling regulations in most countries currently relate
to pre-packaged foods, new legislation is set to come into effect
in the EU at the end of 2014 which will require food companies
to provide allergen information for unpackaged foods (e.g. in
bakeries, delis and catering establishments). Modifications to
existing requirements for labelling pre-packaged foodstuffs will
also be part of this legislation.