In 2020, undeclared allergens accounted for a whopping 47% of all Australian food recalls.
In 2019 undeclared allergens made up 37% of all Australian food recalls.
In 2018, undeclared allergens made up 46% of all Australian food recalls.
A food recall is any action taken to remove unsafe or unsuitable food from distribution, sale, and consumption. There are two levels of a food recall – let’s explore them:
- Trade-level Recall – when food has not become available for direct purchase by the public, e.g. has been sold to wholesalers
- Consumer-level Recall – when food has been made available to the public for sale e.g. has made it to shop shelves.
Over 75% of recalls are consumer recalls. This tells us that consumers (the people buying your food product) are having negative experiences after purchasing and consuming your product. Strengthening your allergen management systems and processes will protect your consumers and reduce the likelihood of them having at best, a poor experience of your product and at worst, experiencing allergic reactions and illness, or worse. You want your customers to trust that the product you manufacture is safe and of a consistently high quality.
Between 2011 – 2020, over 85% of recalls in Australia were consumer recalls.
The figures remain relatively consistent when comparing the past decade of food recalls across Australia and New Zealand. While you could say these statistics demonstrate that food manufacturers are not improving, when you dive a bit deeper, there is more to it.
Most organisations believe that they have good food safety management systems in place. By looking at the root cause of real-life recalls and learning from others’ mistakes we gain useful information to see where our gaps may be.
What are the Top Four Allergen Recall Root Causes?
- Lack of skills and knowledge of Labelling requirements and Food ingredients
- Supplier Verification issues
- Labelling and Packaging Errors
- Cross Contamination
Let’s explore these reasons in detail and the reasons that attribute to these four main errors.
Lack of Skills and Knowledge of Labelling Requirements and Food Ingredients
Food regulations change frequently. It is important to ensure your systems, processes and people (employees) are up to date and updates flow to all systems including ingredients, product specification lists, labelling and artwork. Ensure suitable checks are in place for products exported to different countries as each country has different requirements (overseas market access regulations / OMARs).
Example: Pasta was declared as an ingredient, but wheat was not declared as an allergen. Example: Manufacturer reformulated their ingredients – however, they did not reflect the new ingredients on the labelling.
Example: Ingredients were not fully translated into English from the original language.
Supplier Verification Issues
Auditing your suppliers is vital to check the ingredients supplied to you consistently meet all requirements and specifications. Conducting a Vulnerability Assessment will evaluate the potential risks and gaps in your supply chain. Produco is experienced in conducting these checks and identify gaps that may exist in your supply chain.
Example: Raw ingredient contained an allergen but this information was not passed on to the manufacturer.
Labelling and Packaging Errors
Ensure your labelling and artwork is compliant with the export market requirements. These are often different across countries. Ensure that you have strict version control of your documentation and have an independent person complete a second check.
Example: Product packed in the wrong packaging.
Example: Dairy-free claim on the front of a packet. This was meant to be a gluten-free claim. The ingredient list was correct.
Cross Contamination
Cross-contamination either of a raw ingredient, or during the final production process can be costly to your business and impact on all products that were manufactured on that processing line. Some of the causes are: inadequate cleaning, poor ingredient labelling, poor storage or handling practices, uncontrolled changes to the production schedule, and poor re-work practices.
So How Robust is your Allergen Management System?
In looking at the above real-life examples, it is apparent that these manufacturers did not have all the controls or expertise in place they should have. A robust allergen management system has many different components; fortunately, most can and should be incorporated into your existing systems and SOPs.
For example, in the recall prompted by the use of wrong packaging, there should have been a formal documented check that the product packaging is correct at the pre-start check and at regular intervals through the run or when changing reel stock.
It is a good idea to have all the allergen management components summarised in a single procedure. This helps with auditing and training but more importantly, forces you to look critically at the process to see what areas need controls. A tip is to follow the manufacturing steps and to include product development, raw material and suppler approval and rework – this helps with identification of any gaps.
