No Nuts Here

05.01.18

Millions of Americans rely on allergen warnings on food labels, but ensuring that these labels are accurate requires a painstaking behind-the-scenes process.

While public awareness of the hazards posed by foodborne allergens is on the rise, so is the prevalence of food allergies themselves. Some 15 million Americans — including 4% of adults and 8% of children — now have a food allergy, and this number is only rising. This is particularly true among the younger set: according to the Centers for Disease Control and Prevention, the number of American children with food allergies increased by nearly 50% between 1997 and 2011.

In response to this trend, Congress passed the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA), which requires producers to label foods that contain a “major food allergen,” including milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans. While keeping the food supply chain free of allergens is easier said than done, the country’s food processors have taken even greater pains to develop and implement comprehensive food safety measures since the adoption of FALCPA, helping the millions of Americans living with a food allergy understand what is safe for them to eat and what is not.

Crafting an Allergen Control Plan

Responsible food production begins with an Allergen Control Plan — a written document that details how a producer will minimize allergen cross-contamination through proper sourcing, storage, handling, processing, and ingredient identification. An Allergen Control Plan must be dynamic, capable of responding to challenges that arise along the supply chain.

The first part of an Allergen Control Plan must address the difficulties inherent in acquiring supplies. Most food manufacturers source their raw materials and ingredients externally, making it difficult to ensure their purity. As a result, it’s important that they carefully review the labels of everything that passes through their doors and push their suppliers for more information — where an ingredient is sourced from, what kind of facility it was previously stored in, what precautions were taken to minimize cross-contamination during transportation, and so on.

Storage considerations come next: allergenic ingredients should be stored separately in clean, sealed containers. Or, if space is limited, the possibility of accidental cross-contamination can be lowered simply by storing non-allergens above allergens and storing similar allergens — milk and whey, for instance — together. Color-coded storage containers or some other system of organization is just as essential to guaranteeing proper storage of allergenic ingredients, especially in tight quarters.

Thoughtful production scheduling and plant design are no less important than careful storage protocol. Ideally, every plant would have dedicated processing equipment for each allergen it handles, but most manufacturers don’t enjoy this luxury. As such, food producers should schedule long processing runs to minimize the number of times employees have to adjust their handling protocols, separate equipment that processes products with allergenic ingredients from equipment that does not, and clean processing equipment immediately after it comes into contact with an allergen.

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The Importance of Proper Labeling

After a producer has drawn up an Allergen Control Plan that addresses all of these considerations, they must label their finished products clearly and appropriately. Not only does improper labeling expose producers to legal liability and costly scandals, it also puts the health and wellbeing of millions of consumers at risk. The accuracy and comprehensibility of food packaging labels is paramount to avoiding allergen-related incidences.

While it’s tempting for producers to overuse precautionary allergen statements like “May contain…” or “Processed in a facility that…” the FDA highly discourages — and in some circumstances prohibits — the use of these statements as a substitute for proper production and labeling practices, and with good reason. When producers begin to treat precautionary allergen statements as a way to dodge legal liability, the number of food options available to consumers with food allergies drastically decreases. Consequently, these consumers may ignore such allergen warnings, taking on unnecessary risks for the sake of convenience.

Ultimately, it’s up to every food manufacturer to find a way to ensure the health and wellbeing of their consumers without compromising their bottom line. This task is undoubtedly complex, but with a well-considered, comprehensive Allergen Control Plan, every producer can maintain a food production operation that’s as efficient and cost-effective as it is transparent and cross-contamination free.