As a food-safety lawyer, these three words send shivers down my spine. They are all exceptionally difficult to routinely control in products regulated by the USDA Food Safety and Inspection Service (FSIS). Almost invariably, at least one of these three words is featured prominently in recalls.
In 2007, there were only 14 recalls involving undeclared allergens in U.S. Food Safety and Inspection Service (FSIS)-regulated foods. This year, there have already been 60 recalls involving nearly 10 million pounds of product.