Managing Food Allergens in the Retail Supply Chain

1. Managing Food Allergens in the Retail Supply Chain John Points Consultant Scientist

2. Contents What do we mean – manage? Risk Assessment Risk Management Dealing with incidents

3. What do we mean – manage? Customers can be confident that if it is not on the label, it is not in the food. A non-competitive issue: consumer trust in food affects everybody

4. A significant risk to manage Worst-case impacts Product recall Brand damage Fatalities / Hospitilisations (Direct costs £100K - £5M) (long-term loss of trust)

5. What do we mean – retail supply chain?

6. Part of the retail supply chain Processed Raw Materials Supermarket own-brand recipes Manufacturer’s Site Simple Raw Materials I will concentrate on own-brand manufacturing Smaller specialist suppliers “Artisan” brands Manufacturer’s branded product Retail

7. How retailers assure standards Formal Standards – Specified in Trading Contracts Audit and Inspection (surveillance testing) (complaints trends) GFSI Certification Schemes Retailers’ own Standards Certification Bodies In-house audit team

8. Raw Materials - Allergenic Assessment BRC SALSA

9. Inventory of allergens on site

10. Typical visualisation Grid of which products contain which allergen (either as an ingredient or as an unavoidable RM cross-contaminant) Red – need to protect the product from any source of this allergen

11. Risk assessment – routes of contamination Some sectors have higher inherent risk than others – what can you control? Bakery Meat

12. Risk Management Does NOT mean Alibi Labelling Seen as protecting the retailer, rather than protecting the consumer Applied inconsistently – people no longer believe it (or, if they do, would overly restrict choice for those with allergies)

13. (unjustified “May Contain….” labelling will be precluded by BRC v8, from February 2019)

14. Risk Management - Training Every new employee and contractor receives allergen management training before starting work

15. Risk Management - segregation

16. Risk Management – physical segregation Keep the allergenic ingredient away from non-allergenic products OR Keep the non-allergenic product away from everything else Tools & equipment Storage Air-flows People-flows

17. Risk Management – time segregation Manufacture products with allergenic ingredient AFTER those without Rigorous cleaning procedures before re-start of non-allergenic product

18. Cleaning Validation & Verification Mix of on-site test kits and laboratory tests – ensure no allergen is left on equipment or surfaces Sometimes 30+ tests before the line restarts

19. Extra requirements for Free-From Depends on the Retailer’s Policy Some retailers don’t allow the allergen on site • or on any of the raw material suppliers sites Some allow it, but in separate buildings / lines Exceptions – uneconomic to have a separate line • e.g. gluten-free Christmas puddings • extensive cleaning and verification protocols All require extensive testing of RMs and product • some require positive-release testing

20. Despite all this …………. More cases of allergen recalls due to mis-packs than to cross-contamination Entirely avoidable Much more hazardous than cross-contamination (or – even more frustrating – allergen label not printed in the local language)

21. When the worst happens – what does a retailer do? All supermarkets have well-practiced and formal procedures for incident impact-assessment and control. (weekly occurrence, for the Big 4: no need for war-games practice!)

22. Retailer assesses the hazard and the impact Examples: increasing hazard, increasing impact Notification from FSA or industry – confirmed allergen in competitor product from same supplier Confirmed mis-pack or customer complaint Surveillance test result – trace of allergen found (may have been occurring for years!) Notification from supplier – weakness or failure in segregation or cleaning procedures Notification from supplier – confirmed trace contamination in a raw material batch Notification from supplier – weakness or failure in packaging inventory control system Discretion No discretion Retailer’s Options Continue sale – but fix the problem at source Stop supply – but sell through existing stock Point of sale hold– whilst investigating or assessing further Withdraw stock – but no publicity or recall Recall Within discretion, different retailers have different approaches to publicity / recalls (brand protection vs erring on side of caution)

23. Impact Assessment – Example Scenario Surveillance test finds unlabeled egg 10-20 ppb in raw prawn crackers Used in a variety of foods across many ranges – snacks and ready-meals Calculations show that it breaches the VITAL2 limit But: Products have been on sale for years – no reported complaints Huge analytical uncertainty on test result – different test kit detects no egg Recall would be massive – range of products, volume of sales, long shelf-life Withdraw or recall? Only have a few hours to make the decision

24. Recalls – a slick process Pre-written templates: in-store notices, press releases Pre-written communication: FSA, other retailers, allergy action groups Automated point-of-sale blocks Loyalty card data – direct e-mail to customers who bought the product (~40% return rate, compared to ~20% for press-release notices) Pre-written briefs for customer careline operators, store managers Avoid drip-by-drip recalls: one recall notice, all affected products, industry-wide.

25. Is it effective? UK fatal allergens have been catering, not retail (touch wood)

26. Is it consistent? Incidents as collated on https://horizon-scan.fera.co.uk, data analysis by John Points

27. Summary Allergens are well-controlled in UK retail • given the volume of sales, there are relatively few incidents Certification and assurance schemes give consumers confidence Even with the best schemes, incidents still happen • Procedures to deal with incidents are effective and fast Retailers need to make major decisions on uncertain analytical data

28. Thank You john.points@btinternet.com