Managing recalls: A long road

by Len Heflich
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Food allergens
Progress has been made, but much more must be done to eliminate allergen contamination.
 

KANSAS CITY — Allergen recalls are an ongoing issue in bakery products. This frustrating situation is one the industry has invested significant time and money for programs and training to eliminate the risk of producing mislabeled products.

Like most difficult problems, this one is complex. There are elements of risk occurring along the entire supply chain, and the industry is composed of many kinds of organizations that vary in size and resources. Baking operations range from small setups, in-store bakeries and medium-sized commercial bakeries to large, multi-plant baking companies. Each of these faces its own challenges. Any solution will need to address all sizes of facilities, and industry data might provide some useful patterns to focus improvement efforts on.

The data for the past eight years show that bakery products account for about 18% of all food recalls. Focusing on allergen recalls alone, baking represents about 35% of them with no indication of improvement during this period. The Food and Drug Administration (F.D.A.) is in the process of identifying “high-risk industries” for closer inspection and has unofficially indicated that the baking industry’s performance on allergens could be a factor.

Total recall

The past three years show consistent allergen contamination in the food industry, but the products vary, and patterns are hard to establish.

There were 437 food product recalls in 2015, with 39 attributed to bakery products and 32 of these were blamed on allergens. Fourteen recalls were from milk, seven from undeclared peanuts, seven tree nuts, seven egg, four soy and two wheat allergens.

In 2016, there were 540 food product recalls total, with 96 attributed to bakery products, and 56 of those from allergens. Peanuts were involved in 22 of these bakery product recalls, with all but one of them resulting from a single incident. Another 22 allergen recalls were due to unlabeled milk, while nine were from egg, seven tree nut, two soy and two wheat allergens.

Food and beverage product recalls
 

There have been 275 food product recalls through mid-August of 2017, with 44 from baking products and 33 of these blamed on allergens. Sixteen of the bakery recalls were due to tree nuts, 12 milk, six egg, three soy, three peanut, one fish and one wheat.

The good news is that there were no reports of consumer injury from these recalls. When companies discovered an issue, they voluntarily took rapid and effective action to remove mislabeled products from the market. Baked goods are unique because most producers have quick access to the market. Unfortunately, that’s where the good news ends.

The bad news is that bakery recalls for allergens have been a persistent problem for many years, with little to no sign of decline. But where is the problem, and how can the industry solve it? There are several points in the process where unlabeled allergens can be mistakenly introduced. To reverse this trend, effective controls can prevent these errors and detect them quickly if a failure occurs.

Unwrapping the recall riddle

Mislabeling is the biggest cause of allergen recalls in baking. Despite constant updates to finished product labels, the industry has been bombarded with changes due to regulatory requirements for genetically modified ingredients, dietary fiber definition, Nutrition Facts Panel update, vending label update, added sugar labeling and folic acid calculation. Add to these company-initiated changes for new formulations, promotions, etc., and the burden of label maintenance is huge and costly.

The level of regulatory change in labeling is unprecedented and bound to cause consumer confusion. Every time a label is updated, there is a risk of an error somewhere along the chain of implementation. Segregation of packaging in storage and use is an example of a best practice that companies use to ensure that packages don’t get mixed. Some companies have installed scanners at the final step to guarantee the right packaging is used.

When an ingredient supplier produces and ships an allergen-contaminated product to its bakery customers, recalls skyrocket. This happened in 2016 with a peanut contamination in wheat flour, a single event that resulted in 21 peanut-related recalls. The flour flowed from mill to customer to secondary customer to retailers and into an ever-expanding array of consumer products. The recalls lasted from April 20 to July 15 with two clusters in April and June to July. It is suspected that the wheat going into the flour mill became contaminated during shipping, possibly in a rail car, with peanut residue.

Allergen-related food and beverage product recalls
 

The level of peanut protein in the finished products was low, and allergic consumers reported two minor reactions. The industry dodged a bullet and learned it needs better management of rail cars used to transport peanuts and their residue. The industry is seeking a system to ensure cars are adequately segregated or cleaned prior to being used to haul a different food ingredient, but fragmented ownership and control of rail cars makes this challenging.

Although allergen recalls continue, there are no apparent patterns or trends when it comes to specific products or categories. Recalls affect bakeries of all sizes.

The American Bakers Association (A.B.A.) offers numerous resources for education related to allergen management for its member companies. In 2017, 20 of baking’s 33 allergen recalls are from companies not involved in the A.B.A., and 12 are from supermarket in-store bakeries. Two recalls were attributed to A.B.A. members. Similar overall numbers were reported in 2016.

Lee Sanders, senior vice-president of government affairs and public affairs for the A.B.A., insists that food safety is not a competitive issue.

“Food safety is the highest priority for our members, and allergen management is part of that critical equation,” Ms. Sanders said. “As we discuss these issues with our members, we approach them with allergic customers and consumers as a priority.”

Another resource is the Food Allergy Research and Resource Program (F.A.R.R.P.) at the University of Nebraska, Lincoln, and Steve Taylor, PhD., or Joe Baumert, PhD. “At F.A.R.R.P., we pride ourselves in working cooperatively with all segments of the food industry, including the baking industry, to share our expertise and knowledge of best practices,” Dr. Taylor said. “We would welcome the opportunity to work with a wider array of baking companies.”

Establishing a model

Large- and medium-sized bakeries have shared their best practices at industry meetings over the past 20 years. The A.B.A. has collected best practices from these companies as well as from other industry leaders, in a white paper published on www.americanbakers.org.

The strategy is based on several key steps. First, bakers should formulate products to “all contain” or “all eliminate” allergens as much as possible. Then, minimize the number of allergen changeovers performed by scheduling, moving production and more. Employees must be trained on the risks involved in handling allergens. A comprehensive vendor management program is important because a supplier problem quickly becomes a baker’s or co-manufacturer’s problem. A structured change management process can ensure the accuracy of labels, as will segregating allergen ingredients and packaging in storage and on the bakery floor. A comprehensive assessment will identify potential allergen risks and what next steps are required. Finally, a bakery must know how to test traceability of ingredients into products and products back to ingredients.

The baking industry’s combat of allergen contamination is not yet a success, although there are indications that some might have it figured out.

Clearly, continued failures are not acceptable, so the industry must seek new solutions. In some cases, new risks such as the peanut contamination in wheat flour have identified the root cause and set corrective actions that will prevent the failure from happening again.

When working properly, the system will expose uncontrolled risks when a failure occurs. Industry has responded rapidly and effectively when a failure was detected. During the peanut contamination, the F.D.A. communicated effectively via the Product Registry. The potentially contaminated products were removed quickly from the market, preventing harm to sensitive consumers.

A.B.A. member companies share best practices in food safety openly, as a failure anywhere in the baking industry negatively impacts everyone. Small- or medium-sized baking companies, those new to the industry, or those with questions about how to implement an effective allergen management program can reach out to the A.B.A., AIB International, Independent Bakers Association, Retail Bakers of America or even their own suppliers to learn about proven best practices.

The expertise is available. All bakers need to do is reach out and make it a priority to end allergen recalls.

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