Preventing the shipment of mislabeled meat and poultry with undeclared allergens
Nothing to sneeze at: Processors that prevent the shipment of mislabeled meat and poultry with undeclared allergens can avoid the costly ramifications of product recalls and damaged reputations.
Recalls can have a devastating effect on meat and poultry processors.
Removing proteins from commerce because of adulteration or misbranding can potentially cost operators millions of dollars and negatively impact companies’ standings, making it vital for operators to sharpen their focus on product ingredients and labeling.
“Small processors cannot afford a recall and probably cannot survive an illness outbreak” because of mishaps, states Christopher Young, executive director of the Elizabethtown, Pa.-based American Association of Meat Processors (AAMP).
Milk, eggs, fish (including bass, flounder and cod), crustacean shellfish (such as crab, lobster and shrimp), tree nuts (including almonds, walnuts and pecans), peanuts, wheat and soybeans account for 90 percent of food allergic reactions, reports the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS).
Indeed, such allergenic ingredients as nonfat dry milk and hydrolyzed wheat protein often can be found in processed meat and poultry, including hot dogs and chicken nuggets, the FSIS notes.
Factors causing incidents include suppliers not alerting processors to ingredient or formulation changes; negligence by companies in updating labels after modifications; processor confusion when handling products with a similar appearance or functionality but different formulations; and exporters not knowing all the countries that designate a specific ingredient as an allergen, says Brittney Bullard, a partner in Allied Food Safety LLC, a Los Angeles-based consulting firm focusing on food safety, quality control and regulatory compliance.
Additional triggers are the substitution of ingredients without label reviews; using the wrong label or packaging during production; and processors not following proper cleaning procedures, which can result in cross-contamination of allergens, says KatieRose McCullough, director, regulatory and scientific affairs, for the Washington, D.C.-based North American Meat Institute (NAMI).
“The biggest challenge is ensuring accurate communication throughout the supply chain, from ingredient manufacturers to distributors to packaging suppliers to co-packers and processors,” McCullough states. “Label verifications at each point in the supply chain can help identify when something is awry.”
Processors also can better prevent occurrences by forging strong relationships with their suppliers, which includes having “robust conversations” and incorporating a system of checks and balances, Bullard says. Among such measures are the use of formulation sheets that verify the ingredients in use during production; comparing actual ingredients with label data before products ship; and documenting that processors are following the proper production methodologies, she notes.
Educate the employees
While Bullard says that every plant has “unique operating challenges,” she states that larger operators are in better position to minimize recalls because of having more workers available to focus on threats.
“Smaller buildings may have just two or three people who are doing six or seven other things,” she says.
In addition to having the necessary staffing to properly monitor activities, processors need strong training schemes so that workers “grasp the importance” of accurate labeling and the need to eliminate undeclared allergens from proteins, Bullard states.
“But the quality of employees also is crucial,” she says. “Companies with great training programs still can have problems from workers not following proper procedures. Employees have to realize that product checks are part of their jobs, and processors must constantly verify workers’ competency, particularly in locations with high employee turnover.”
In addition, operators should separate the production of products with allergens from non-allergenic items “by time and space,” Young says, which can include delaying processing of allergenic meats until the last shift so that plant cleaning crews can sanitize work areas before the next day’s activities begin.
Processors, meanwhile, can also reduce cross-contamination and mislabeling incidents by using color-coded equipment to help ensure that the processing of proteins with specific allergens only occurs on certain devices, and removing all labels and packaging materials from work areas before starting production on new products, Bullard states.
“It is important that incorrect materials are not accessible,” she notes.