Issue #54 | Tragic and Preventable Death | Allergen Recalls from Around the World | Fraud Corner
2022-09-05
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Why we care about food allergens, and how things go wrong
What (exactly) is an allergen recall and what are the main causes of allergen recalls
Allergen recalls global stats for 2022
Allergen tools, e-books and webinars
Food Safety News Roundup
Food fraud incidents, updates and emerging issues
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Hi, Happy Monday,
Welcome to Issue #54 of The Rotten Apple, and a big welcome and 💚 thank you 💚 to our new paying subscribers, including our first (paying) Canadian, hello! I use the funds from subscriptions to find and research the best food safety and food fraud news from around the world, so I can deliver insightful, independent emails without the PR fluff and advertorials you find in ‘normal’ industry newsletters.
Food Fraud (Trello) Database Announcement
For those of you familiar with the Food Fraud Risk Information Database on Trello, I have an important announcement. From 1st September we are no longer posting (close-to) real-time food fraud incident reports on the Trello board. We will keep updating information for individual foods/ingredients when new risks or new emerging food fraud trends become known, but the “Recent Incidents” columns have been discontinued.
The food fraud incident reporting that was found on Trello is now available only in this newsletter, or for purchasers of downloadable offline 'snapshots' of the database, which are published six times per year here.
Issue #54 is an allergen special and includes a guest post from Dr Steven Gendel, an eminent food safety expert and the first Food Allergen Coordinator at the US FDA. If you are curious about why food allergens are such a big deal in food safety, and wondering how various global regions compare in terms of allergen management, you’ve come to the right place.
Allergens also feature in this week’s news and resources round-up which includes a generous selection of free allergen-related resources, including on-demand webinars, a live webinar and the FAO Code of Practice for allergen management for food businesses.
I hope you find it interesting and useful. Enjoy!
Karen
P.S. If you’re new here, hi, nice to ‘meet’ you! Find out more about this newsletter (and subscribe) today.
Allergen Special
Why We Care About Food Allergens
Five years ago, Celia Marsh died after eating a sandwich that was supposed to be dairy-free in a restaurant in the United Kingdom. She was allergic to milk. Unfortunately, the coconut-based yoghurt-style dressing on the sandwich contained traces of milk protein.
A pre-inquest hearing last month heard there was a ‘mismatch’ between the allergen information supplied by the manufacturer of the coconut dressing and the distributors of the dressing. The inquest, which starts on Wednesday, will try to discover if the risk of milk contamination in the dressing was properly passed on to the makers of the sandwich.
The coconut yoghurt maker issued an allergy alert and recalled its products after it was investigated by British Food Standards Agency in the wake of Ms Marsh’s death. However, they say the recall was not linked to the incident.
It’s easy to imagine how a terrible accident like this could happen. The coconut product manufacturer might have known there could be traces of dairy in the product, but the distributor of the product who sold it to the sandwich company might not have received that information, or they could have received it but not conveyed it to the sandwich company. Or the sandwich company might have received information that the dressing might contain traces of milk, but may not have passed that information on to consumers.
Or perhaps the coconut product maker might have unknowingly used ingredients contaminated with dairy products. Reports of dairy contamination in coconut milks, creams and waters are not uncommon, and some have been attributed to fraudulent adulteration.
At this point, we don’t know exactly how the milk proteins came to be in the sandwich that Ms Marsh believed was safe for her to eat. The coroner will try to answer that question in the coming weeks.
What (Exactly) is an Allergen Recall?
Allergen-related problems cause a significant proportion of food recalls internationally, with between one-third and three-quarters of all food recalls being attributed to allergens. Allergen recalls are expensive, preventable, and if not done fast enough, can result in deadly consequences for allergic consumers.
An allergen recall happens when a food business or government agency discovers a food safety risk to consumers who are allergic to common human food allergens. Because allergic reactions can be fatal, the presence of allergens is considered to be a significant food safety risk. The food must therefore be removed (‘recalled’) from the market to reduce the chance it will be eaten by an at-risk consumer.
There are two common scenarios that prompt allergen-related recalls. One is when an allergen is found unexpectedly in food… by ‘unexpectedly’ I mean the allergen is a contaminant. In this case, the allergen has got into the food, usually after the food or its ingredients have contacted an allergen-containing food or a food-handling surface like a conveyor belt that has been used for handling allergenic ingredients.
The second scenario is when the allergen was present on purpose – not there due to a contamination event – but the food was not labelled correctly.
In both scenarios, there is a food safety risk because allergic consumers will not be aware of the presence of allergens.
Food can be labelled incorrectly if a product is
accidentally packed in the wrong packaging, or
if the artwork on the label accidentally includes the wrong allergen claims, for example, a dairy-free claim instead of a gluten-free claim,
or if there is a mistake in the ingredient list.
Mistakes with labels cause around half of all allergn-related recalls in Australia.
Allergen-related Food Recalls (2022) - Around the World
Dr. Steven M. Gendel, of Gendel Food Safety LLC, spent more than two decades developing science and policy at the US FDA and was the first FDA Food Allergen Coordinator. He has researched the numbers on allergen recalls for 2022 from across the globe and it’s not looking good. Here’s Steven’s report on allergen recalls.
“Controlling and properly labeling food allergens have been major problems for the food industry worldwide for many years. An analysis of allergen-related recalls and notifications during the first half of 2022 shows that this unfortunate trend continues and that the problems that were seen before the pandemic are still major health threats for the vulnerable allergic population.
In the US, food allergen recalls are reported by the Food and Drug Administration (FDA) and the USDA Food Safety and Inspection Service (FSIS). During the first six months of 2022 allergen-related recalls accounted for 35% of all recalls for FDA regulated food products. This was about 1.5 times as many recalls as were triggered by Salmonella and twice as many as were triggered by Listeria. Similarly, 39% of recalls for FSIS regulated food products were for allergen-related problems, while 22% were for microbial contamination. Most of the FSIS allergen recalls were for complex meat-containing products, such as frozen pizzas.
The three allergens most often associated with the FDA recalls were milk, wheat, and eggs. These were closely followed by recalls that involved multiple allergens. Bakery items were the most frequent type of food recalled for allergen problems. Candy and ice cream products were almost as frequent.
In Canada, allergen problems were responsible for just over 30% of all food recalls in early 2022. Milk was again the allergen most often cited in the allergen recall description, at 56% of the allergen recalls. Not surprisingly, it looks as if the Canadian food industry has the same allergen control problems as the US industry.
In the United Kingdom, which now reports recalls separately from the EU, 77% of the reported food alerts in the first half of 2022 involved food allergens. Of these 25% involved milk.
In the Southern hemisphere, Australia reported 55% of their food recalls were allergen related and that 26% involved milk.
The situation in the European Union is more complex. The Rapid Alert System for Food and Feed (RASFF) collects information on five types of notifications involving a wide variety of products, including many that are animal health problems. For example, the RASFF contains notices related to the movement of live animals between countries. This makes it difficult to compare the percent of allergen related RASFF alerts to recalls elsewhere.
Nonetheless, the RASFF database contains 28 notifications dated between January 1 through June 1 that involve allergens. Of these, milk, gluten, and soy each were involved in 18% of these notifications.
What can we learn from this, and how can we use these lessons to improve allergen control?
First, recall data are the most important source of information on the "reasonably likely" public health risks linked to weak allergen controls and allergen mislabeling. Understanding patterns of allergen recalls and alerts is as important for protecting vulnerable allergic consumers as is outbreak data for estimating risks from food borne pathogens.
Second, clearly allergen control continues to be a food safety problem world-wide. This shows that it is important for each producer to have strong supply chain controls that recognize the potential for undeclared allergens to enter the supply for multiple reasons. Further, manufacturers need supply chain controls that recognize the possibility that their suppliers may not be aware of the presence of undeclared allergens. The most effective tool to reduce or eliminate allergen supply chain problems is a well-designed sampling and testing program. This is a situation where the concept of "trust but verify" is a useful approach.
Third, manufacturers should use information on allergen recalls, alerts, enforcement actions, and other regulatory notices to assess their vulnerability. However, while data on broad industry trends is useful, evaluating data on specific ingredients and products can help ensure that resources are used efficiently and effectively.
Fourth, it is striking that milk is the most problematic food allergen world-wide. This likely reflects the many ways that milk and milk-derivatives are used as ingredients and the wide variety of foods where they occur. It also suggests that there are many ways that undeclared milk can be incorporated into a product.
Fifth, it is disappointing that there is almost no effort being made to determine and share information on the root causes of allergen recalls. Root cause information is essential for implementing a truly preventive approach to allergen control. Without this knowledge, it is impossible to learn from experience.
The only regulatory agency that reports root cause data is Food Standards Australia and New Zealand (FSANZ), which posts aggregated food recall statistics. The statistics for 2021 show that more than 60% of allergen-related recalls were caused by packaging errors and supply chain problems. This re-emphasizes the importance of looking beyond sanitation and cross-contact issues when designing and implementing allergen controls.
The take-home lesson from this look at allergen recalls is that allergen problems are a real threat to public health, that they occur everywhere in the food system, and that sound allergen controls are essential to protect products, businesses, and vulnerable consumers.”
🍏 Thank you, Dr. Gendel for sharing your allergen knowledge. Find Steven at www.gendelfoodsafety.com or connect with him on LinkedIn. 🍏
Re-visit: An Awesome Free Tool for Allergen Management
This is a re-post from Issue #30 in March 2022, about a fabulous interactive tool for food allergen management. It is an interactive map of a food manufacturing facility. Food professionals can use it to learn about where allergen risks occur in a facility and how to reduce the risks.
The tool includes tips and advice for all aspects of food manufacturing, from the R&D pilot plant to equipment design, cleaning and best practices for managing rework.
The map was created by the Allergen Bureau, an Australian food industry body, but is relevant for food manufacturing in all countries.
🍏 Access it here: https://info.allergenbureau.net/infographic/ 🍏
News and Resources
Our news and (free) resources section is now in a standalone post. Expertly curated and free from filler, fluff and promotional junk. Click the preview box below to access it.
What you missed in last week’s email
· Threats to Food Safety from Cyber Attacks
· Pathogenic E. coli in Leafy Greens - a root cause analysis
· The Food Safety Aspects of Sous Vide (for paying subscribers)
· The Big Four Companies Benefitting from High Commodity Prices
Below for paying subscribers: Food fraud news, incident reports, and emerging issues, plus an 🎧 awesome audio version 🎧 (so you can catch up while on the go)
📌 Food Fraud News 📌
Whole Foods USA is being sued over its claim ‘No Antibiotics Ever’ in beef
The plaintiff, an organisation that campaigns against “factory farms” claims it found
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