SGS sets out starting point for food safety plan

The firm said it must be known what is in the ingredient provided and what changes have been or will be made to it.

It added 17 of the first 25 US Food and Drug Administration (FDA) food recalls in 2015 were because of undeclared allergens.

Provision must also cover prompt notification if/when the ingredient is no longer in compliance with regulations or food safety standards.

When changes are or are going to be made, the ingredient company must ensure any change resulting in a something being added or removed are notified to companies using the altered ingredient, said SGS.

Changing the ingredient statement on the packaging/label may not be sufficient, because the receiver may not have a proper program to review labels and check they match what they were expecting to receive. Without this detail, they cannot make appropriate changes in their product.

On the receiving side, no product should be used without verification it is in compliance and the ingredients are as listed on the specification, no matter how urgently it is needed.

Undeclared nut proteins in spices​

Most of the recalls were because of an undeclared peanut protein in ground cumin which was not declared on the ingredient statement.

The cumin supplier and provider has said no peanuts or peanut materials are in the facility, so it is not known if the issue was caused by unintentional or intentional contamination.

Meanwhile, the Canadian Food Inspection Agency (CFIA) found results which prompted cumin products to be recalled for containing almond were wrong and positive readings were caused by mahaleb.

Liquid Chromatography-Tandem Mass Spectrometry (LC-MS/MS) was the confirmatory test and false positive results were determined using the Enzyme Linked Immunoassays (ELISA) method.

Bart Ingredients and the UK Food Standards Agency (FSA) are awaiting results from the Lab of the Government Chemist (LGC) on a recall due to almond concerns.

The firm said results which prompted a recall on its ground cumin could be due to mahaleb.

Europe has also been affected with France, Belgium, the UK and Denmark issuing recalls for products contaminated with almond without mentioning it on the packaging.

Belgium became involved when it recalled spices due to peanut trace findings in March.

Reasons for recalls​

SGS said reasons for undeclared allergen recalls vary, but have common factors such as contamination during production, an undeclared allergen in a raw material because of product change or incorrect labeling.

In production, there is the risk of unintentional contamination as well as intentional for economic gain, or to create harm.

It is possible to put processes in place to reduce the impact, or risk with the most important being making sure that rework with allergens only goes into those products it is designed to be in.

SGS recommended validating cleaning programs and verifying cleaning is performed according to the program.

Allergen testing is required for validation and it can also be useful for verification.

Testing of the finished product for potential allergen contamination may be useful, as a pass/fail release, but should not be relied on for replacement of allergen process controls. 

SGS said mistakes will happen, but having an atmosphere that allows an employee to state a mistake has been made, without repercussion, will prevent them being hidden, only to be discovered when the product is no longer under the control of the facility. 

Root cause analysis can identify why mistakes happen. Corrective action and preventative actions must be developed to prevent any recurrence. Continuous improvement is essential and requires internal and external audits to review operations and procedures, it added.