Lessons Learned Jennifer L. Johnson, Ph.D. Director of Food Safety & Quality Salm Partners LLC
Allergen-related Recalls of FSIS-inspected Products
Canadian Recalls (all foods) Keep good records and review them prior to shipping product From http://www.inspection.gc.ca/english/corpaffr/relations/res/statrece.shtml
Recalls due to Ingredient Issues • “The company changed ingredient suppliers, and the label was not changed to reflect the new ingredients” • “The problem was discovered by FSIS during a routine label review, when it was determined that the label read lecithin, not “soy lecithin” as it should”
Recalls due to Ingredient Issues • “Company changed ingredient suppliers and began using Worcestershire sauce, which contains anchovy puree, in its ingredient blend. The company’s label lists Worcestershire Sauce as an ingredient, but failed to list anchovy puree” • “The inspector noticed the use of sour cream in making dough for the products, but no indication of milk as an ingredient on the label”
Lesson 1: know your ingredients • Never change ingredient suppliers unless you have verified that the “new” ingredient matches the “old” ingredient • Request ingredient label & specification in advance of potential change • Check these documents against label approval & finished product label • Audit labels on first incoming load of “new” ingredient prior to releasing for use in production • Be specific when labeling lecithin, starch, etc. • Anchovy-containing Worcestershire Sauce should be avoided whenever possible
Lesson 1a: understand typical ingredient composition • Not unreasonable to expect, for example, that • An egg roll wrapper contains egg • Teriyaki sauce contains wheat & soy
Recalls due to Label Issues • “The problem was discovered by the company during a label review, and occurred because of a printing error made by its label maker” • “The problem… occurred because the spice blend used in the products contained cultured whey as an ingredient, which the company inadvertently left off the product label”
Lesson 2: ingredient statements on labeled packaging must be accurate • Know how your labels & labeled film are printed • Gang printing? • QA checks – type & extent of checks • Always review label proofs for accuracy • Audit incoming labeled packaging by comparing its ingredient statement to • Finished product specifications • Label approvals • Labels on incoming ingredients
Recalls due to improperly labeled Product • “The problem occurred when a company employee used labels from items produced earlier on the same day in similar packaging” • “The product label indicates that the can contains Chicken Noodle Soup; however, it may contain Cream of Chicken Soup” • “Southwest Style Chicken product packages may instead contain Chicken Pasta Pomodoro, which contains an undeclared allergen, egg”
Lesson 3: always put the right label on product • Line extensions are a special concern • Consider use of 2-D bar codes on label/labeled film coupled with in-line bar-code readers programmed with specific product bar codes
Lesson 4: assembling kits requires inclusion of the correct components • Recalls of meat/poultry-containing meal/snack kits due to incorrect pre-packaged sauce, dressing, or dessert component
Who initially discovers allergen-related issues leading to recalls?
Lesson 5: review records prior to shipping product
Lesson 6: train all personnel on allergen control • Increased awareness benefits everyone and makes it more likely that errors will be caught before product leaves the establishment’s control • Recall of duck products with sauce identified by a Distribution Center • Recall of chicken breast patties with undeclared Isolated Soy Product identified by company accountants while performing routine weekly checks on production yields
Lessons from allergen-related recalls • Know your ingredients • Pay special attention to formula expectations • Ingredient statements on finished products must always be accurate • Always put the right label on the product • Assembling kits requires inclusion of the correct, properly-labeled components • Review records prior to shipping product • Train all employees on allergen control
FSIS Allergen Guidance Materials • FSIS Notice 54-11 (9/28/11)http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/54-11.pdf • FSIS Notice 35-11 (7/7/11)http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/35-11.pdf • FSIS Directive 8080.1 Rev. 6 Attachment 2 (10/26/10) http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/8080.1.pdf
FSIS Allergen Guidance Materials • Voluntary Labeling Policy (3/15/07) http://www.fsis.usda.gov/Regulations_&_Policies/Labeling_Allergens/index.asp • Federal Register Notice (5/8/06) http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/05-016N.pdf • Q&A related to Ingredients of Public Health Concern (11/8/05) http://www.fsis.usda.gov/regulations_&_policies/FAQs_for_Notice_45-05/index.asp
