When we talk about food safety, one almost always thinks about foodborne illness, but preventing allergen cross-contact along the supply chain is just as critical. 

Allergen cross-contact happens when an allergen is accidentally transferred from one food to another directly, through food contact surfaces, or even via airflow. The possibility that a food contains allergens from cross-contact or mislabeling is a leading cause of recalls, according to the Food and Drug Administration’s Center for Food Safety and Applied Nutrition.

This blog from ImEPIK will look at federal food safety regulations that address allergen cross-contact, in addition to what manufacturers need to know to protect consumers from potential allergic reactions.

FDA Oversight of Food Allergens

The list of major food allergens that must be identified on food labels is included in the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA)

The major food allergens covered by FALCPA (as well as ingredients containing proteins derived from them) are:

  • Milk
  • Egg
  • Fish
  • Crustacean shellfish
  • Tree nuts
  • Wheat
  • Peanuts
  • Soybeans

Under the FASTER Act of 2021, sesame will become the 9th major food allergen on January 1, 2023.

allergen cross-contactCross-contact of allergens can happen at multiple points in the supply chain, from the farm level to a restaurant, retailer, or consumer’s home. This blog will focus on manufacturing and processing facilities.

Although allergens must be included on food labels, that is just one step of the process.

Manufacturers must address potential problems through current Good Manufacturing Practices (cGMPs). Those GMPs should:

  • Identify allergens; and
  • Detail allergen cross-contact prevention protocols.

A company’s Hazard Analysis and Risk-based Preventive Controls (HARPC) plan will address these potential allergen cross-contact hazards.

The following areas of potential allergen cross-contact highlight what food manufacturers should be concerned about in their operations.

Storage, handling, and flow of ingredients through a facility

GMPs should look at the “big picture” areas of food safety, including how a facility’s layout affects the flow of ingredients.

Questions one might ask include: 

  • How and where are allergen-containing ingredients stored, and are they properly labeled? 
  • Are those ingredients handled in a way that keeps traces from becoming airborne or contacting equipment that’s not part of their processing? 

GMPs must address the movement of these ingredients from receiving to processing and beyond to packaging and shipping.

Environmental and human cross-contact

Interaction between an employee and an allergen-containing food ingredient is a potential cross-contact event. Forklift drivers, processing equipment operators, and others that handle the allergen can inadvertently taint other food ingredients through a spill, adding an incorrect ingredient during processing, or transferring proteins from one food to another through clothing. Food handlers, maintenance workers, and even visitors need to follow food safety practices.

Vacuums and ventilation systems can also help control dry allergens, such as flour.

Dedication, separation, scheduling, and sanitation

Ideally, food manufacturers would allow for dedicated facilities to make products that don’t contain allergens, increasing the likelihood those products won’t have a cross-contact problem. However, when that’s not possible, or allergens are ingredients in the products, companies can use separate processing lines to keep the allergen-free products apart from those containing allergens.

A facility may also sequence production so that food containing allergens is processed last and only after products that do not contain allergens. Of course, a thorough sanitation process must follow before any other non-allergenic products are made. 

ImEPIK’s training on allergen cross-contact and food safety musts

ImEPIK’s 100% online training course is designed to help companies in the U.S. meet the obligations of the Food Safety Modernization Act. A similar course for employees of Canadian companies focuses on Safe Food for Canadians Regulations.

The 100% online interactive courses allow employees to learn at their own pace and practice what they learn through project-based activities that maximize engagement and understanding.

Contact us today to learn more about how our courses can keep you in compliance with the latest regulatory requirements.

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