Allergen control and microbiological testing guidance for meat industry

The documents are from Colorado State University's Center for Meat Safety and Quality with the North American Meat Institute (NAMI) and funded by the Beef Checkoff.

The Beef Checkoff Program is a producer-funded marketing and research program to increase domestic and/or international demand.

In the last five years, undeclared allergens have been the leading cause of recalls in the meat industry, said the guidance.

Allergen control concerns​

In the allergen control guidance​, the most likely reason for failure to declare an allergen on a label is a change in product formulation or in the supplier’s ingredient formulation.

The only way to prevent is to ensure allergen control programs are adequate and properly implemented.

In April 2014, FSIS published a guidance document, which provides recommendations for identifying allergens and other ingredients of health concern during a hazard analysis.

If the analysis determines the hazard is reasonably likely to occur, controls for allergens must be in the HACCP plan through one or more CCPs.

If the hazard is not reasonably likely to occur, controls may be in the SSOP or other prerequisite program.

Good Manufacturing Practices (GMP) should be followed during production, said the document.

“Specifically, employees need to know when to change frocks and gloves; when to wash hands; how to comply with SSOPs; in addition to documenting and preparing records demonstrating compliance; and ensuring employees are aware when allergens will be used in production.”​

If scheduling a separate production day for products with allergens is not feasible, establishments should consider producing allergen containing items at the end of the day.

Production at this time eliminates a full sanitation of exposed production areas and equipment between product line changes.

If allergen containing products cannot be made at the end or on a dedicated day, the guidance set out actions for product manufacturing and packaging areas and advised keeping records of sanitation procedures.

Proper storage of allergens is necessary to reduce the potential for cross-contamination.

“If allergens must be stored in the same location as non-allergen ingredients, they should be stored on the bottom shelf or on a separate shelf to reduce the likelihood of cross contamination. All products and ingredients containing allergens should be marked in a conspicuous manner for easy identification by employees during storage and handling.”​

Employees must receive sanitation training to ensure the plant is adequately cleaned after production, said the guidance.

“The product being produced, food contact surfaces used, and the allergen(s) hazards should all be considered when designing a sanitation program. Food proteins, which are the source of allergic reactions, can be difficult to properly remove from food contact surfaces.”​

Test kits may be used as a tool for periodic verification; however, they are not the best tool for ongoing allergen control monitoring, according to the document.

In some cases, the level of sensitivity for an allergen test exceeds the threshold associated with adverse reactions.

Testing alone typically is not considered conclusive evidence the allergen is not present because it might not be homogeneously distributed through a product.

Microbial testing ​

For the guidance on selecting a lab to do microbiological testing​, it said it is the firm’s responsibility to ensure the lab (in-house or third-party) is knowledgeable in methods used and can provide accurate results.

“​For example, the laboratory personnel should understand how intrinsic factors, e.g. fat, pH, or water activity, and extrinsic factors, e.g. environmental sanitizers, can influence method sensitivity. ​

“When selecting a method, laboratory personnel should understand the method’s limitations, including detection limits.”​

The laboratory must know and understand the Microbiology Laboratory Guidebook (MLG) because the methods it describes are used by FSIS laboratories.

A rapid in-plant testing kit may meet AOAC or ISO standards, but if it does not ensure detection capabilities are at least as sensitive as the FSIS MLG method, screen testing of the product may not be considered sufficient for the intended use by FSIS.

AOAC or ISO certified methods and labs provide additional reassurance that analyses are handled correctly. However, establishments must ensure the proper method is being correctly used. 

Complicating the decision-making is that many methods and labs are not AOAC or ISO “certified,” but can provide excellent and accurate services.

“To be clear, cheaper is not always better. Obtaining or generating laboratory results, supportable for the intended purpose, is paramount,” ​concluded the guidance.