All data used in this post was found on the website of the Canadian Food Inspection Agency (CFIA).
An internal communication error between product formulation and Quality Assurance (QA) might allow a change of ingredients to go without a change in labelling. A whole list of things might happen.
What makes this issue all the more serious for food manufacturers is the fact that the authorities treat allergens as a black-and-white issue. Declared presence = no recall; undeclared presence = recall. And those recalls that are announced tend to be designated the highest severity; for example, 94% of Canadian Food Inspection Agency (CFIA) recall alerts for undeclared allergens last year were designated Class I, which means they were deemed as ‘high risk’ and likely to cause bodily injury or even death.
So which allergens are slipping through the QA net? When thinking allergens, we often go straight to peanuts and shellfish. However, in 2016 these accounted for just 3% of undeclared allergen recall alerts in Canada. There are likely two factors at play here – the first is that these ingredients are not used in as many products as other allergens, therefore the number of products which could be affected is far smaller. The second is that the severe consequences of exposure to peanuts or shellfish for someone who is allergic has led to these being better controlled.
According to the CFIA, our big four allergens for slipping through unnoticed in 2016 are, in order of frequency:
Egg, milk, wheat and… mustard.
Milk and egg are by far the most frequent, making up 60% and 52% of recall alerts in 2016 and 2017 respectively. Given the Class I status, recalls of these products tend to be well publicised and can be financially traumatic for a manufacturer’s finances and brand.
It is vital that labelling is brought to the forefront of QA team’s thoughts and that one single person is responsible for all labelling content. Ensure you have rights of recourse and indemnity agreements with labelling suppliers and designers so that you can pass the costs of their mistakes to them in the event of a labelling issue. Formula and ingredient changes, as well as supplier changes, should all involve the QA Manager’s sign-off on labelling. Speaking of suppliers, make sure your ingredient suppliers take it as seriously as you do! A company with the best labelling checks in the world will still be undone by a mislabelling at its supplier’s facility. Awareness training could be a way to ensure both staff and suppliers are fully informed and educated about the risks and prevention methods.
This content is purely informational and is not intended to be used as legal guidance or advice.
