133 | Top 10 Root Causes of Allergen Recalls | ATP Testing |
133 | Top 10 Root Causes of Allergen Recalls | ATP Testing |
Plus, pasta-flavoured ice cream and dates for our next meetup
Save the date: Meet-up on Thursday/Friday this week;
ATP testing in food safety - an introduction;
Top 10 root causes of allergen-related recalls;
Food Safety News and Resources;
Mac n Cheese Ice Cream (Just for fun);
Food fraud news, emerging issues and recent incidents
Wow, thank you so much! 👏👏 Russell from New Zealand and M the mystery man 👏👏 became paying subscribers last week, and Hernan, Karen, Kaieyan, Julie, Kathryn, Ina, Omar, Hannah, Maria, Sophie and JS all continued their paid subscriptions. I couldn’t do this newsletter without your financial support, thank you!
Welcome to Issue 133 of The Rotten Apple. Our April meetup is on Thursday the 11th, or Friday 12th this week - depending on your timezone. Save the date.
This week’s issue explains ATP testing for those of you who need a reminder or an introduction, plus a dive into the top causes of allergen-related food recalls. And silly-flavoured dairy desserts.
Have a wonderful week,
Karen
P.S. If you love this newsletter, please tell your friends and colleagues about it and help grow our community of global food safety champions.
Save the date: Meetup 11th/12th April, 2024
Our next meetup is on Thursday 11th April (Friday morning for Australia and Asia). Everyone is welcome.
ATP Testing in Food Safety Systems
… an introduction (or reminder)
ATP testing is a technology used for measuring the cleanliness of surfaces in food-handling environments. ATP test systems can detect traces of the chemical ATP on the surface being tested. ATP is adenosine triphosphate, a molecule found in all living cells. It is also present in materials that were once living, including food.
ATP testing systems are kits which include an electronic device, disposable swabs for rubbing across surfaces and supporting accessories such as calibration systems and reagents.
Compared to traditional microbial surface swabs, ATP testing is much faster, providing instant results. However, ATP tests give positive results if any organic matter is present on a surface, whether or not it is from microorganisms or food debris. Because both living cells and non-living cells contain ATP, ATP testing cannot show whether any microorganisms on a surface are ‘alive’ or ‘dead’.
ATP testing can be used to detect the presence of organic material, such as food debris or microbial biofilm on a surface.
Microbial techniques provide different information to ATP tests. They can differentiate between viable and non-viable microorganisms and food residues. They can also provide more quantitative information, and be used to identify the presence of specific pathogens or indicator organisms on a surface. However, they take a lot longer to yield results than ATP testing.
ATP test results are reported in relative light units (RLUs) which correspond to the amount of light released during an enzyme-mediated reaction inside the test unit. The more ATP in the sample, the more light is emitted and the higher the number of RLUs recorded by the device. Higher readings therefore indicate more organic matter in the sample, and indicate a dirtier surface than samples with lower RLU results.
What ATP tests can do:
Indicate the presence of organic material on a surface;
Monitor the effectiveness of cleaning and sanitation processes;
Provide almost-instant results, so corrective actions can be taken immediately;
Enhance training of cleaning staff, because results provide an objective and instant measure of success;
Aid in deep-cleaning processes such as when disassembling machinery, to identify problem areas.
What ATP tests cannot do:
Distinguish between ‘living’ and ‘dead’ organic matter;
Indicate the presence of low numbers of microorganisms or specific pathogens;
Indicate the presence of inorganic dusts, dirts or fibers;
Enumerate bacteria or other microorganisms on surfaces.
How does the food industry use ATP testing?
ATP testing is usually conducted in-house, by the food company’s personnel. It is used for verifying that surfaces have been properly cleaned before they are sanitised, and for environmental monitoring programs.
ATP swabbing can be used to measure the cleanliness of direct food contact surfaces such as slicers, utensils, conveyor belts; indirect food contact areas, such as parts of machines adjacent to food streams; hard-to-clean areas such as nozzles, grooves, joints and O-rings; and environmental areas such as walls, floors and drains.
How much do ATP test systems cost?
A fact sheet published by the Institute of Food Safety at Cornell University in February 2024 explains the costs of ATP testing to food businesses. Prices are in US dollars.
“There are initial costs upfront and then ongoing costs as you perform [ATP] testing. Luminometers range from ~$1,500 to $3,500. Sometimes the luminometer purchase includes swabs, which increases the cost. Swabs usually come in a case of 100 swabs and range in cost from ~$225 to $360 per case. The enzyme solutions that are part of the swab will expire. This is important to consider when purchasing swabs. Additional materials include calibration kits, positive controls, and carrying cases. Some of the luminometers include software that will link to your computer so you can keep electronic records.”
5 facts you might not know about ATP tests:
At least 1,000 bacterial cells (10^3) must be present in a sample for there to be enough ATP to be detected by commercial ATP testing systems (source).
ATP tests recreate the chemical reactions that produce bioluminescence in marine bacteria and fireflies, making use of the naturally occurring enzyme luciferase (source).
The numerical results delivered by one brand of ATP test equipment will be different to another brand’s unit. Pass/fail levels need to be set based on the test unit used, and can’t automatically be used with different brands or models of testing device.
Some sanitisers interfere with the ATP bioluminescence reaction (source).
ATP tests can be used for water quality testing, including for recreational waterways, by indicating the presence of biological contamination (source).
Top 10 Root Causes for Allergen Recalls
Allergen-related recalls are among the most common food safety recalls globally. They are the most common recall type in the United Kingdom, and the second most common type in the United States. In Australia and New Zealand, recalls due to allergen-related labelling errors are the most common type, followed by other allergen-related causes (Source: RQA Group (2024) Product Recall Report).
Why do we recall food for allergens? Foods that contain allergens which aren’t listed on the label - whether due to cross-contamination or from labelling errors - can cause fatal reactions in allergic individuals. It’s a huge food safety problem.
Past issues of this publication have explored the circumstances surrounding the death of Celia Marsh in the United Kingdom and Anna Bellasario in Italy who both died from anaphylactic shock after being exposed to dairy proteins in ‘plant-based’ meals. Other recent cases include James Atkinson in Australia (peanut in pizza) and Órla Baxendale in the USA (undeclared peanuts in cookies).
Here are the top 10 root causes of allergen-related food recalls, according to a SQF technical reviewer and certified auditor. Examples have been added by me.
Packaging errors: using incorrect or outdated labels or packaging materials that do not match the actual product or ingredients.
🍏 Example: The peanut-in-cookie fatality in the US is rumoured to have occurred because the supplier of the bulk (unpackaged) cookies had informed the retailer that the formulation had changed to contain peanuts, but the retailer, who was packaging and labelling the cookies, had somehow failed to update the label artwork or had used old artwork (source: insider).
Supplier verification issues: receiving incorrect or incomplete information from suppliers or failing to verify the allergen status of raw materials or ingredients.
🍏 Example: Celia Marsh’s inquest uncovered a possible ‘mismatch’ between the allergen information supplied by the manufacturer of the coconut dressing used on the sandwich she ate and the distributors of the dressing.
Accidental cross-contamination: introducing allergens during production, processing, storage, or transport of food products, due to inadequate cleaning, segregation, or control measures.
Lack of staff skills and knowledge: not having sufficient training, awareness, or competence to fulfil the labelling requirements or to prevent allergen contamination.
🍏 Example: Staff at the cafe where Anna Bellasario died had been questioned by her about allergens before she ordered.
Recipe or formulation changes: altering the ingredients or composition of a product without updating the label or notifying the customers.
Labelling omissions or errors: omitting, misstating, or mistranslating the allergen information on the label or in the product information.
🍏 Example: Nut mixes were recalled in the USA in January 2024 after a mix-up during packaging. A ‘party mix’ product was placed into a tin with a ‘deluxe mix’ label. The party mix contained allergens including peanuts, milk, soy, wheat, and sesame which were not listed on the deluxe mix label.
Regulatory changes or differences: not complying with the latest or relevant regulations or standards for allergen labelling or management in different markets or jurisdictions.
🍏 Example: Did you know that different countries have different lists of allergens for cautionary labelling? Celery, mustard and kiwifruit are food allergens with regulatory status in some countries but not others.
Product substitution or adulteration: replacing or adding an ingredient that contains an allergen without disclosing it on the label or in the product information.
🍏 Example: Meat products allegedly fraudulently adulterated with high levels of undeclared sulphites caused an “allergic-like reaction” in a consumer in Slovenia in 2019.
Analytical testing issues: using unreliable, inaccurate, or inappropriate methods or equipment to test for the presence or absence of allergens.
Consumer complaints or reports: receiving feedback or evidence from consumers or third parties that indicate the presence of undeclared allergens in a product.
Takeaways for food professionals
When allergens are involved, mistakes can be both costly and deadly.
Labelling errors, ommissions and mix-ups are a leading cause of allergen-related recalls. They are entirely preventable.
If your food business handles any notifiable food allergens, or uses any ingredients that could contain traces of allergens, then labelling artwork controls should be a critical control point (CCP) in your food safety system.
Packaging suppliers are also required to have artwork control systems in place under certain GFSI-benchmarked standards. These controls include management of obsolete artwork and superseded printed material.
In short: 🍏 Allergen-related recalls are perhaps the most common type of recall globally 🍏 Recalls are necessary for foods with allergen-related mistakes because of the deadly nature of undeclared allergens for allergic consumers 🍏 Allergen mistakes are frequently attributed to artwork control errors, ommissions and packaging mix-ups 🍏 Other common causes of allergen recalls are miscommunications between suppliers and customers and gaps in staff knowledge 🍏
Food Safety News and Resources
Super interesting stuff happened in #foodsafety last week! An unusual contaminant from Penicillium spoilage* kills people in Japan 😮; a big ice cream brand lets metal pieces through its CCPs🤔; emerging mercury hazards from melting permafrost; beer line aging and the risk of biofilm formation🍺; a free chapter on food defense from a respected (and expensive) book…. and more!
My weekly food safety news roundups are free for everyone. Click the preview below to read.
*maybe
Mac n Cheese Ice Cream (Just for Fun)
Yes, mac n cheese ice cream is a thing. Say the makers: “You know you’ve always wondered what this mash-up would taste like. Or at least you do now.”
Hmmm I’m not sure I am curious enough to actually buy a $12 tub of it…
Below for paying subscribers: Food fraud news, horizon scanning and incident reports
📌 Food Fraud News 📌
📌 Food Fraud News 📌
In this week’s food fraud news:
📌 Food industry insurance and food fraud;
📌 Food crime head interview (video);
📌 Wine counterfeit warning, imported seafood warning;
📌 Illegal grouper fishing, undeclared sulphites cause an allergic reaction, expiry date tampering and more.
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