How Will the New FDA Rules Affect Allergens?
In summer of 2012, the FDA will begin to implement the Food
Safety Modernization Act (FSMA). Allergens are among the hazards
recognized within FSMA. Food companies will be required to have
well-documented preventive controls in place for allergen and other
food safety hazards. At this time, the nature of the preventive controls
that FDA will expect with respect to allergens and the documentation
that will be required to prove that the controls work is unknown. However, some likelihood exists that FDA will require analytical validation
of the effectiveness of the preventive controls. Companies may still be
able to rely on visibly clean specifications if they have documented
that visibly clean equates to analytically clean.
What Foods Are Most Often Contaminated with Allergens?
The most vulnerable foods are those where cleaning to remove allergen residues is challenging. Where wet cleaning and especially CIP
(Clean-In-Place) cleaning can be done, allergen residues can often be
effectively and consistently removed. However, some food manufacturing facilities must be cleaned without use of water. Examples would include baking operations and chocolate manufacturing. In some cases,
Allergen-Free Success Stories
By Kat Schuett
Many companies are getting noticed for being allergen friendly,
some of which offer organic options. Sunbutter offers an organic
sunflower seed butter as a substitute for peanut butter. Others al-
lergen-friendly manufacturers that use organic ingredients are
Amy’s Kitchen and HomeFree. Home-
Free’s low-glycemic Mini Vanilla
Cookies, which come in convenient
single-serving packages, have won nu-
merous accolades including Shape
Magazine’s 2011 Best Snack Award,
About.com’s Reader’s Choice Awards 2012 and the Food &
Beverage Product Innovations 2012 Award presented by
the National Restaurant Association.
Pamela’s Products, a gluten-free leader, also uses some
organic ingredients. One of the company’s latest suc-
cesses has been the Whenever Bar, which is gluten and
dairy free. The company breaks down what other aller-
genic products contain or do not contain on its website
Several “natural” products have had great success, and
while they are not organic, they show how the allergen-free segment is growing. Good Life products, which are
free of the eight most common allergens, certified gluten-free (by the Gluten-Free Certification Organization), recently came out with a snack bar made with Sunbutter.
Additionally, Ian’s Foods has created chicken patties, battered fish and french toast sticks as part of its Red Banner product line, which are all
made without wheat, gluten, casein, milk, eggs, nuts or soy.
HomeFree’s Award Winning
Dairy-Free Whenever Bars
SunButter, a Popular
removal of allergens to a nonde-tectable level is impossible, so advisory labeling such as “may contain…”
is advocated. Bakery goods and confectionary products are common categories involved in recalls for
undeclared allergens. However, virtually any product is vulnerable to packaging and labeling errors.
The good news is that today there
are more dedicated allergen-free facilities in existence than ever before.
For instance, there are now organic
chocolate processors that do not
allow any of the Big 8 allergens into
the facility. Prior to this, almost all organic chocolate had to have allergen
warnings for dairy and nuts, which
are often part of the chocolate-mak-ing process. However, even in self-proclaimed dedicated facilities, it’s always
important to do your homework to
make sure that stringent protocols are
followed. Are employees restricted
from bringing highly allergenic foods,
e.g., peanut butter, in their lunch? Do
vending machines in the company
cafeteria contain highly allergenic
foods? Are there hand-washing stations and people to supervise that
each employee sanitizes prior to entering the production area? Are they
using any processing aids that could
be allergenic? Ask to see written statements and tour the facility.
In regards to gluten-free products,
there are several groups that now offer
gluten-free certification. Looking for
these certified ingredients can provide
additional peace of mind that steps to
avoid contamination are being taken
and verified through an independent
third party. For example, even though
quinoa is naturally gluten-free, some
suppliers process the grain in shared
facilities with products that contain
gluten and thus contamination is possible. To ensure that the product truly
is gluten-free, some suppliers have undergone third-party inspections and
now offer certified gluten-free quinoa.