Components of an Effective Allergen Control Plan

A Framework for Food Processors

When a food safety issue due to mishandling of allergenic ingredients occurs, everyone in the food processing industry suffers. Consumers depend on food companies to provide safe products. Consumers who must be mindful of the foods they eat because of potential allergic reactions are especially dependent on the industry's ability to identify, process, and market foods which are labeled correctly.

Food-allergic consumers must avoid the foods that trigger their allergic reactions. Thus, they rely heavily upon the ingredient statements of packaged food products to identify the products which contain their allergen(s). Labeling of foods for the presence of allergenic foods must identify all foods that intentionally contain the particular food or ingredients derived from that food. However, voluntary labeling for the possible presence of the allergen (e.g. 'may contain x') should be reserved for situations that potentially represent genuine hazards.

In recent years, there has been a proliferation of the use of precautionary allergen statements, which range in wording from "May Contain" and "Processed in a Facility", to "Made on Shared Equipment". This increase has limited consumer food choices. Alarmingly, food-allergic consumers, especially teens, are beginning to ignore precautionary statements, and taking risks regarding the food they choose to eat. This can lead to trouble for both the consumer and the industry.

An Allergen Control Plan is a critical component in your product safety initiatives. You must do everything within your power to ensure allergenic foods and ingredients do not find their way into products for which they are not intended. Your Allergen Control Plan is your company's written document regarding the storage, handling, processing, packaging, and identification of allergenic foods and ingredients.

This is not a one-time effort. Your Allergen Control Plan must be implemented, audited, enforced and updated continually. Every time you make a change in a process or a product, assess your plan and update as needed. Every time you hire a new employee or change the responsibilities of an employee, make certain they understand their role in the Allergen Control Plan through documented training. Every time you begin working with a new supplier, evaluate their Allergen Control plan and change yours as needed. If you change or add locations, a new Allergen Control Plan should be developed specifically for that location.

This document is not intended to be comprehensive by any means. The intent is to provide food processing companies with a framework for an Allergen Control Plan - and an introduction to the issues and considerations which are typically included in such a plan.

Not all recommendations are applicable to all food processing companies. Still, it is important to consider each recommendation and determine the extent to which it may apply to you or your suppliers - and then create the appropriate procedures in the Allergen Control Plan that will help your plant.

An Allergen Control Plan is about protecting the health and confidence of consumers. But it is also about protecting the financial health and reputation of your company.

We hope this document is valuable to you and your team as you create the Allergen Control Plan for your company.