This month the USDA/FSIS issued Notice 45-05 . This notice called for the inspection personnel to verify that plants have appropriate process controls in place for allergenic ingredients. Inspectors are to look at the flow chart and hazard analysis to see if products have allergenic ingredients and what, if any, controls the plant has in place. The notice does allow for the control of allergenic ingredients to be in the HACCP plan, SOPs, SSOPs, or Prerequisite programs.
What’s the concern?
A food allergen is defined as “a product or ingredient containing certain proteins that can potentially cause severe (occasionally fatal) reactions in a food allergic person. The basic agent of the allergen is the protein. These proteins cannot be eliminated through the cooking process. It is estimated that at least 2% of the adult population experience food allergies. There are 8 food types containing proteins that cause 90% of the allergic reactions. These 8 food types are: milk, eggs, peanuts, tree nuts, fish, shellfish, soy, and wheat.
How are they controlled?
There are 4 areas of operation in the plant that can be effectively monitored to control food allergens. These are: Receiving/Storage of ingredients, Formulation of ingredients, Rework utilization, and Labeling of finished products.
- At receiving of ingredients it is important to make sure that ingredients are properly labeled. If prepackaged spice blends are being used, it is important to make sure that one of the 8 allergens hasn’t been added to the blend without notification or that a substitute blend has been sent to your plant.
- During storage of ingredients, ingredient packaging materials should remain closed when not in use. This will minimize the possibility to the allergens becoming airborne, which could contaminate other ingredients or equipment in the room. Closure can be as simple as rolling the bag and securing the lid flaps on the box. Holding bags shut with tape is also easy to do.
- Formulation of product ingredients is done differently in many plants. If all spices, etc. are being weighed out, it is important that monitoring of added ingredients is done. This can be accomplished by checking of ingredients from the formulation sheet as they are weighed out. This helps to make sure the proper ingredients are added as well as the proper amounts being weighed out. If prepackaged spice blends are utilized, it is important to monitor that the correct bag is being added to the product being produced. Many bags may have similar product names but different ingredients.
- Rework can be a dangerous meat source if proper precautions are not used. If finished product is used as rework it is very important that the formulations for the two (or more) products have the same ingredients. It could be very easy to have allergen ingredients (listed above) in one formulation and not in another similar product. Use of mismatched rework could cause severe allergic reactions for susceptible customer, as the allergen ingredient may not be on the finished product label.
- Labeling of the finished products is the last stage at which to check ingredients. It is very important to have the formulation sheet in hand when selecting and printing the labels. A comparison of the ingredients listed on both the formulation sheet and the selected label should take place. Unlisted ingredients (other than those from cross-contamination) could severe allergic reactions for susceptible customer, as the allergen ingredient may not be on the finished product label.
These seem like simple things to do in a production operation however, if the procedures are not written out with a schedule to follow, they will most likely be forgotten. A well written program should include a justification of the program, control limits, monitoring procedures and frequencies, and corrective actions. We are all trying to produce a safe food product. This is an aspect of the food safety system in the plant that should not be overlooked.
Ryan R. Baumert
HACCP Specialist
A213 Animal Science
(888)-688-4346
7/28/05
