Allergen Labeling Challenges

The first article in this two-part series is focused on how enterprise business solutions can help food processors manage industry challenges around the current enacted regulations in the 2004 Food Allergen Labeling and Consumer Protection Act. This FDA legislation addresses better management and disclosure of food allergens in the manufactured foods we eat every day. In addition to regulations that are in place today, such as requiring disclosure of food allergens on product labels by manufacturers, food processors know there are further regulations outlined in this legislation which are scheduled to go into effect in the near future. This article focuses on how enterprise business solutions can also help food processors comply with these upcoming new guidelines, related to managing the presence and disclosure of protein-based allergens during the manufacturing process, for food products they make, move and store.

One such challenge facing food processors is the pending enactment of regulations targeting the prevention of inadvertent cross-contamination of food allergens into unrelated food products being produced around the same time, often using the same processing equipment. Environmental cross-contamination, i.e., the introduction of protein-based food allergens into normally allergen-free food products, can occur when a product, without allergens in its recipe, is processed on the same manufacturing line after a food product whose formula contains milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat or soybeans, without the necessary level of cleaning processing equipment between production runs.

Consider the example of a hypothetical cookie manufacturer who makes both peanut butter and sugar cookies. During production, making both types of cookies often includes similar processing steps; mixing separate batches of cookie dough for each kind of cookie, forming individual cookie shapes, baking cookies in the oven, and finally packaging one or more package sizes for each produced flavor of cookie. When sales demand and available inventory supply levels dictate, both kinds of cookies may end up being made on the same day, even in direct processing sequence, one after the other. It’s also likely that some or all of the same production equipment will be used to manufacture many types of cookies, allowing food processors consistent quality while being as efficient and cost-effective as possible, i.e., making the best use of capital equipment investments. As a result, both allergen- and non-allergen-based food products often utilize the same production line, during the same workday and shift.

Now imagine the potential exposure of cross-contamination for allergen and non-allergen based foods if the first production run scheduled for the day on a shared processing line is for peanut butter cookies. As peanut butter cookie dough leaves mixing, passes through cookie shaping, moving directly into a cooking oven, and finally on to packaging, peanut residue remains behind on each piece of equipment used. Upcoming enactment of regulations in the Food Allergen Act focus on minimizing the risk of such allergen residue potentially ending up in subsequent batches of non-allergen food products – products whose formulas and package labels don’t specify the presence of these allergen ingredients (in this example, preventing peanuts from ending up in sugar cookies).

So how can enterprise business applications help? Pending enactment of these regulations will require voluntary compliance by food processors, including the addition more sophisticated quality control-mandated sanitation and changeover procedures for production equipment and operations as a key part of manufacturing processing. This includes having employee training instructions in place to support adherence to food allergen prevention-based procedures. This provides increased awareness about when and how to clean equipment during changeovers and between production runs to prevent cross-contamination of food allergens. In this example, it means integrating procedures about when to clean the mixer, shaper, oven and packaging equipment after making peanut butter cookies and prior to beginning sugar cookie production, along with related operational instructions about how to perform these operations.