The recall numbers for 2014 have been tabulated by the USDA. All total, there were 94 recalls in the year, totaling 18,675,102 pounds of products. Of those, 43 were due to an undeclared allergen in the product, leading to a recall of 6,147,288 pounds of meat.

While every recall is a frustrating, costly event, the ones tied to misbranded products have to be among the worst. Those six million pounds of food could have been eaten by an overwhelming majority of the American consumers with no ill effects. For the people with food allergies, though, a misbranded product can be a dangerous, even life-threatening item. If someone with a peanut allergy unknowingly ate a sausage that contained nuts and went into an anaphylactic shock, they could die if not treated quickly enough.

For all the concern about food allergies, a processor can still produce items with eggs, nuts, cheese or some other allergen without trouble, as long as they label their products correctly and follow good manufacturing practices involving those ingredients.

“Allergens are not a hazard in properly labeled product,” says Andrew Lorenz, president of We R Food Safety consulting group.

He points out several common factors behind allergen-related recalls, such as a supplier that changes its ingredients list to now include an allergen but fails to notify processors of the change. Lorenz recommends that companies maintain strong relationships with their ingredient suppliers and to request that they be notified in advance of any formulation changes that would add allergens to a product.

“In today’s world there is no excuse for finding out that your supplier changed their ingredients after they shipped the product to you,” he says. “If your suppliers don’t want to provide you prior notification, find a different supplier; it is that simple. Remember, you are the one who is going to end up with your good name out on the recall. Just because you used them forever doesn’t justify them not providing you great service!”

Recently, there have been more than a dozen recalls due to one seasoning, cumin, which was potentially contaminated with peanuts. Unfortunately, Lorenz notes that there is no practical way to prevent this from happening, as testing each batch that comes in could be prohibitively expensive, and conducting third-party audits of the supplier would not be effective.

“For those reasons I recommend that not only does the producer have insurance, that they require their suppliers to have insurance as well,” he says.
When it comes to in-plant processes, Lorenz says that companies should schedule their production runs based on ingredients to avoid cross-contamination.
“For example if you make sausage, produce non-allergen containing products first, then the one with milk powder, and then the one with milk powder and soy. That way you don’t have to do an extra clean up and you don’t have to worry about incidental contamination,” he says.

Many processors already segregate allergy-causing ingredients in their facilities, but Lorenz says that workers should go a step further and mark all such packages with something noticeable, such as a bright orange sticker or a large “S” for soy, as an example, written on it in marker.

“Everyone who is in the facility should know that if it has the orange dot sticker or other ID that it contains an allergen. While this seems like a waste of time it is not; it pays for itself by avoiding just one allergen recall,” he adds.

Since rush jobs and custom orders are part of the norm for many processors, it is not uncommon for a product with allergen to get inserted into a production schedule. Having those visible cues around will help remind workers that when they finish producing a particular product, they will have to thoroughly clean all the equipment to avoid cross-contamination.

Whatever system a company uses, it has to be simple enough for everyone to understand, and the management has to stress the importance of following set procedures for dealing with allergens. Lorenz notes that if the boss takes something seriously, the employees quickly will learn to take it seriously as well.

Awareness also needs to be a part of the packaging process. In that final step, a product that has made it safely through the entire process could become a recall risk if the incorrect label is applied.

“Reviewing labels should be a normal part of your packaging and labeling work flow,” Lorenz says. “Every employee that applies labels should be checking to make sure they are using the right ones. It is a normal part of their duties.”