It is crucial that food manufacturers and distributors effectively control for allergens. Our experts offer guidance for managing allergens in the supply chain.
Allergen awareness – and the training needed around it – are big concerns for the food industry. Businesses are working hard to put processes in place that keep consumers safe, providing high quality, correctly labelled food products served by food safety-trained staff.
But with food labelling laws constantly evolving, there is always space for more education, especially around the dangers of different allergens. Even traces of something like a peanut, can cause a severe reaction, so supply chain safety must be stringent. Only last month a UK dancer in New York lost her life when she had an allergic reaction to peanuts in a mislabelled cookie.
And while you can have control over what happens in your own business, you may not have a clear picture of what your suppliers are doing. In this article, we’ll be exploring the issue of allergens in supply chain management, and how businesses can ensure safety and transparency at each stage of the supply chain.
What allergens could be present in the supply chain?
The FDA recognises nine major food allergens: Dairy products, peanuts, tree nuts, shellfish and crustaceans, fish, gluten, soybeans, sesame seeds, and eggs. EU and UK regulators, on the other hand, add celery, lupins, mustard, sulphites and sulphur dioxide to the list for a total of 14 major allergens. While guidelines introduced by Food Standards Australia New Zealand in 2021 require nine tree nuts, ten common allergens and four gluten and sulphites to be noted in their allergen labelling.
Expectations for allergen management in the food industry
Each country has its own set of laws governing food safety and allergen management. European food and drink guidelines include regulations that aim to minimise the chances of allergen cross-contamination. These include:
- Quantifying the concentration of allergens that may be present in food ingredients so that manufacturers can assess risks.
- If allergen-containing ingredients are used as raw materials, staff should be fully trained in allergen management.
- Processes should be designed to minimise cross-contamination risks and should be strictly followed at all times.
- Specific procedures should be followed so that products or ingredients cannot be inadvertently exchanged or mislabelled.
The Food and Agriculture Organisation of the United Nations (FAO) captures this in detail in Regulation (EC) No. 852/2004.
In the USA, the FDA’s Food Allergen Labelling and Consumer Protection Act 204 (FSMA) applies and is supplemented by the Food Safety Modernization Act. This comes into effect in January 2026.
Precautionary allergen labelling (PAL), on the other hand, is voluntary. Common examples include statements such as “may contain” or “manufactured in a facility”. However, the FAO warns against using this type of labelling unless there is a real risk. In the US, the FDA says that precautionary notifications cannot be used to replace Current Good Manufacturing Practices (CGMPs). In practical terms, this means that in both the EU and the US, precautionary allergen labelling can’t be used as a shortcut. Instead, the food industry is expected to practise good allergen management and this must extend to all supply chain partners.
How to control for food allergens in the supply chain
The FDA recommends a Hazard Analysis and Critical Control Point (HACCP) system for food safety. It’s a system that has gained international recognition and is based on six principles:
Food industry stakeholders should each conduct their own independent hazard analyses. This involves assembling a team with relevant expertise, developing a list of hazards (such as the presence of allergens) and identifying ways in which each hazard can be controlled. They can require suppliers to produce a certificate of analysis showing that they have tested their produce for the presence of specific allergens.
Determine critical control points (CCPs)
Critical control points indicate the points of a process at which a hazard can be prevented or reduced. When it comes to a hazard in your supply chain, as opposed to one that occurs in your own facility, it would be reasonable to discover what CCPs your supply chain partners implement. So, if cross-contamination is a possibility, what do they do to prevent it, and how and when do they test for contaminants?
Establish critical limits
A critical limit is the threshold below which allergens will not cause adverse health reactions. The World Health Organisation (WHO) has established and published threshold levels for priority allergens in foods. These would represent the critical limits that should not be exceeded. In the US, the FDA implements similar guidance. For example, a product may be termed “gluten free” when it contains less than 20 parts per million (ppm) of gluten.
Establish monitoring procedures
Monitoring processes ensure that CCPs have been well-controlled, and monitoring activities are recorded in detail for verification purposes. Since food businesses are ultimately responsible for end-products, they should check ingredients thoroughly. This includes fastidiously checking that allergen content is below critical limits.
Tips for monitoring suppliers include:
- checking that they have a formal allergen control plan
- requiring guarantees that no undeclared allergens are present
- conducting regular audits to assess whether suppliers’ allergen control plans are effective
- requiring them to inform you about any changes in their products
- validation of their contamination prevention processes.
A supplier survey will help identify the risk you take on when choosing a specific vendor. This could help you answer key questions such as the following:
- Which allergenic products do they process and supply?
- Is shared equipment used when processing allergenic and non-allergenic ingredients?
- What protocols are used to prevent cross-contamination?
- Is there evidence that their employees have undergone allergen safety training?
- Are allergenic ingredients properly sealed and marked?
- How would suppliers address a situation in which damaged packaging may lead to cross-contamination?
You may be wondering if you should test ingredients that are delivered to your facility before using them. The answer to this is that you should - at least, from time to time.
The FAO notes: “There should be a regular review of suppliers to ensure that all ingredients, including multi-component ingredients (e.g. sauces, spice mixes), processing aids, or operations, have not changed in a manner that introduces a new allergenic ingredient or that results in allergen cross-contact. Occasional product testing for undeclared allergens may also be considered as appropriate for verification.”
Establish corrective actions
Under ideal conditions, your diligence in monitoring suppliers’ products and methods should mean that you’re aware of allergen content and any contamination falls within the threshold limits. But, as the FDA points out: “Ideal conditions do not always occur.” If it comes to your attention that unexpected allergens have entered your production lines, you must have a plan of action.
The first and most important step is to ensure that contaminated products do not reach consumers. After that, the steps needed to clean your facility and its equipment so that you can restore normal production must be specified. Responsibility for overseeing these activities and carrying them out must be assigned in advance.
Establish verification procedures
Implementing this principle means that you will verify whether your HACCP system is fit for purpose, and if so, whether it is being implemented correctly. Verifications may include getting input from outside experts as well as observations of what happens in practice.
When it comes to applying HACCP principles to suppliers, your regular audits, checking of documentation from suppliers, and occasional testing of their ingredients should suffice. If they fail to comply or are inconsistent, it’s time to search for alternative suppliers.
Establish documentation and record-keeping procedures
Suppliers should make sure that their documentation includes information that they provide to demonstrate good food allergen management practices. It should include a copy of their HACCP and any certificates of analysis, together with evidence that your business’s representatives studied these documents and are satisfied with their contents.
In addition, you should document any control processes you implemented on receipt of goods. For example, what was received, and the results of visual inspections. You should also record the results of any allergen testing or other verification you implemented to confirm suppliers’ claims.
Monitor your supply chain with Foods Connected
Finding out how supply chain players manage allergens and prevent contamination is only part of the food safety criteria you will consider when choosing suppliers. And since your reputation rests on their processes, obtaining accurate information on all the factors that may affect your products can be incredibly complex.
However, with the right technology on your side, you can achieve supply chain transparency. Use our food compliance software to help you choose the right suppliers, obtain specifications, track supplier changes, and more. We’d love to show you how we can help you minimise supply chain-related risks.
Interested in how our food safety software can help your business? Request a demo today.