Cold Connection


New Push by FSIS to Reduce Undeclared Allergen Food Recalls

Written by Joel Taylor

The Food Safety and Inspection Service (FSIS), under the United States Department of Agriculture (USDA), has begun discussions to address the rising number of food recalls relating to undeclared allergens. FSIS held a public meeting on March 16, 2017, at which GCCA representatives were able to participate in the dialogue between government, industry, and research leaders, learning about what GCCA members can be doing to improve their activities, reducing industry-wide allergen recalls.

The public discussion highlighted the issues associated with undeclared allergens, solutions, and what research is currently being conducted regarding food allergens. Since 2008, there has been an increasing number of undeclared allergen recalls across the industry. FSIS specifically put this meeting together to put an industry focus on the issue moving forward into this year.

GCCA participated in an FSIS meeting on March 16, 2017.

With hundreds of thousands of consumers in the United States affected by food allergens, the issue of cross contamination and undeclared allergens in food products is a serious public health issue. The industry has made great strides, working to address these issues, but issues still remain. Currently only 22 percent of allergen related recalls are because of ingredient related errors or incidental contact. The vast majority, 63 percent, of these recalls are actually due to labeling errors.

FSIS, the Food and Drug Administration (FDA), and invited academics at the public meeting all spoke concerning how the industry could work to improve operations to reduce the economic and health risks associated with food allergens. Listed below is a summary list of recommendations for the industry:

  • Staff Awareness
    • General Lack of knowledge concerning allergens and best practice, train every employee (not just best practices, but why they are performing specific tasks)
  • Supplier and Ingredient Control
    • Industry needs to understand sourcing suppliers, inspect ingredients at establishment, do not rely on suppliers, record and label records of ingredients, maintain approved supplier list, maintain open communications with suppliers, be aware of letters of guarantee (LOGs), identify the process for dealing with change with your suppliers
  • Controlled on site food storage
    • Use color coding for ingredients and products with allergens, store separately, mark product storage
  • Segregated handling and processing
    • When possible, separate allergen processing lines and storage, finish storing packaging and product before transitioning between non-allergen and allergen products on a processing line, ensure 2 part products (“lid and tub”) are controlled
  • Equipment Selection and Use
    • Ensure proper and regular cleaning, employ method of cleaning validation, maintain methods for tracking lot codes, evaluate current cleaning procedures
  • Control of Labels and Packages
    • Ensure label accuracy, install label checking technology systems, do not rely on visual checking methods alone
  • Allergen Audits
    • Conduct regular audits of systems, both in house and third party audits. Audit suppliers routinely to ensure quality and control, carry out routine risk assessments with suppliers
  • Communicate with your customers
    • Communicate concerning product changes and allergen safety information
  • Establish Detection Systems
    • Determine how detection is performed, and what allergen levels your system can detect

Though the issue of undeclared allergen recalls is primarily relevant for processors and manufacturers, it is important for the cold chain industry to understand these issues. With many of the recalls involving milk and dairy products, cold chain industries are easily involved in the strategy to address undeclared allergen related issues.

FSIS recall information and guidelines are detailed in FSIS Directive 8081.1.

For any questions regarding this meeting, related discussions, or how undeclared allergens might affect your operations, please contact GCCA Vice President of Government Affairs Lowell Randel at +1 703 373 4300 (220) or by email at

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