If you take a look at the Food Standards Agency’s Food Alerts page on their website, the majority of product recalls are due to incorrect labelling on packaging. Most of these are because they have omitted to state that an allergen is present in their ingredients list.
There have been several prosecutions of food manufacturers and caterers for just such a reason. The most recent high-profile case was that of a teenage girl , Natasha Ednan-Laperouse, dying from eating a sandwich from Pret a Manger. The allergen information was not visible and she died of anaphylactic shock as a result.
Under UK law at the time, food companies were not required to list the ingredients of food packaged and sold on the same premises. However following the above incident, ‘Natasha’s Law’ is to be introduced by summer 2021. This will make full ingredients labelling for foods pre-packed for direct sale mandatory.
There are 14 food allergens
There are 14 food allergens which you need to be aware of that must be listed on prepackaged food. These are milk, eggs, peanuts, fish, crustaceans, sesame, mustard, sulphites, molluscs, soy, gluten, tree nuts, lupin and celery. How they are labelled is extremely important. For example, previously you might have listed the allergens separately. Now there is a requirement to list the components of an ingredient.
So whereas before an ingredients list might have “wholegrain flour, eggs, butter, sugar” it now must be labelled with the allergens in bold type. For example “wholegrain flour (gluten), eggs, butter (milk), sugar.”
Do your labels tell the truth?
You must also be absolutely sure that if you’re claiming that a product is gluten-free, for example, it really is. So, if you produce large volumes of ginger biscuits, but you also produce a gluten-free version of your ginger biscuits, you need to take stringent precautions so that traces of the with-gluten product don’t contaminate the gluten-free version.
This might mean producing the two products in different buildings, but if they are produced on the same line or in the same production area, you have to be completely sure that everything has been cleaned down properly and that staff are briefed in allergen management.
Otherwise, you will need to add a disclaimer on your primary packaging which says something to the effect of: “Manufactured in an environment where products containing gluten are also produced.”
Make sure staff have the correct training
Some people are so sensitive to allergens that only a tiny particle can cause them to have an allergic reaction. Happily we deliver a couple of one-day courses that can help you to ensure that you manage food allergens effectively and label your products correctly and legally.
Our Managing Food Allergens in Manufacturing course is aimed at those who are responsible for designing, implementing and auditing allergen management systems. Using examples, it explains essential aspects of allergen control in food manufacturing. On successful completion of the course candidates will receive the FDQ Practical Allergen Awareness Certificate.
Our Legal Labelling course is particularly popular. It has been designed to give you a working knowledge of the legislative requirements for food composition and labelling. By the close of the course you should have the confidence to assess product specifications, pack copy and artwork for legality. The course is appropriate for Specification Technologists, Technical Managers, Product Developers, Label Designers and those responsible for approving artwork.
Both courses are tutored by industry professionals who have a wealth of practical hands-on experience in their particular fields.
Avoid costly product recalls
Any company which has ever had to recall products will tell you that it is a costly process, through lost revenue and wasted product. It can also have wider consequences in terms of customer confidence, particularly if the media become involved. However, with the correct training, such instances can be avoided in the first place.
To find out more about our Legal Labelling and Managing Food Allergens courses, please visit the Specialist Courses section of our website. You will also find other useful courses such as Root Cause Analysis and VACCP and TACCP.