Recommendations for risk reduction (i)

The experiences accumulated over the years in allergen risk prevention in the food industry confirm that the most common causes of allergen risk management failures are:

• Products packaged in incorrectly labeled containers.

• Products packaged in incorrect packaging.

• Unintentional presence of allergens in the product.

For the prevention and analysis of food allergy incidents, guides have been developed for the prevention and verification of errors, which allow food industry operators to have an additional tool for their allergen risk management program. It can also be a useful tool to determine the origin of a food allergy incident.

Potential Problem: Product packaged in incorrectly labeled packaging.

Critical preventive element: Information in the product specification. Good practice considerations:

• Correct information is available from the supplier, on allergenic derivatives intentionally present and risks of cross-contamination.

• The meaning of the information provided by the supplier is adequately understood.

Example: Whey/milk protein. Versions are effectively controlled.

Example: Use of outdated supplier specification:

• Information is correctly transferred to the recipe/mill list.

• There is transparency regarding: allergenic ingredients of compound ingredients.

• Processing aids containing allergens are declared.

• Risks are assessed for each production line, in terms of allergen cross-contamination.

• The change of allergens in products made on different lines is managed.

• Allergen labeling reflects (worst case allergen labeling) at the different production sites if the product was marketed in different markets due to consumer brand recognition.

• Risks arising from the need to transfer allergen warnings from the supplier to the product are assessed.

• Allergen changes in formulas, ingredients or production are managed.

• Substitution of ingredients is checked for their impact on the allergen profile.

• The European Union allergen reference list is used.

• Supplier or finished product specifications are complete and available.
• Personnel are responsible for checking and approving the bill of materials, formula and specifications.

Critical preventive element: Transfer of allergen information to designs, websites or other media. Best Practice Considerations:

• Staff is competent, responsible for checking accuracy and context.

• Changes in specifications drive changes in labels.

• Specification and design systems are linked and checked.

• Information is correctly transferred from formula to label design.

• Allergen naming is accurately stated on multi-language packaging, words are used correctly and there is consistency between languages.

• Allergen information in the ingredient list is correctly highlighted or reproduced in the `contains` box if used.

• Information on the inne