Food allergen control: discussing the issues with Melanie Neumann

For World Allergy Day we sat down with the food safety risk specialist and food law attorney Melanie Neumann to talk about safeguarding consumers, allergen incidents and the “black holes” in food safety.

Today an estimated 250 million people around the globe suffer from a food allergy. It is an issue that affects consumers everywhere. In the US around 33 million Americans, among them 5.6 million children under the age of 18, contend with food allergies, while between 11-26 million Europeans are believed to be sufferers.

This has led to questions around industry education and labelling. In fact, almost half of adults with a food allergy in the UK say they’ve suffered a reaction due to incorrectly labelled food.

So, what should food safety professionals be doing to safeguard consumers when it comes to allergen control? That’s the question we asked Melanie Neumann, a food safety veteran. An established authority on food safety law and food safety risk management, she has a Masters of Science in Food Safety in addition to her Juris Doctorate in Law and has helped businesses around the world manage their supply chain, specialising in supplier assessment and procurement, business and brand protection, regulatory compliance, and industry best practice.

She believes food safety professionals need to be acutely aware of the three main causes of allergen contamination:

• allergen contaminated ingredients
• allergen cross-contact in the facility
• allergen mislabelling

She explains, “To respond to these causes, food safety professionals need to ensure that they have corresponding procedures to mitigate these risks, such as:

• a robust supplier verification process that specifically includes suppliers’ allergen control practices.
• cleaning and sanitation procedures that are validated and verified to prevent allergen cross-contact.
• label-verification procedures that ensure each product is packaged in the correctly labelled package (e.g., making sure you are not packaging peanut butter ice cream in the container labelled vanilla ice cream).”

To be able to do all this effectively, a traceable food supply chain is critically important.

“Many allergen-related recalls are caused by an upstream supplier of an ingredient used in a finished product,” she says. “Having visibility of every supplier back to the supplier source (and their respective allergen control practices) in the supply chain is the only way manufacturers of finished products can comprehensively mitigate risk of allergen cross contact or allergen mislabeling of its finished products.”

“Having visibility of every supplier back to the supplier source (and their respective allergen control practices) in the supply chain is the only way manufacturers of finished products can comprehensively mitigate risk of allergen”

She cites an incident when peanut shells were added to cumin spice to increase yield without manufacturer knowledge. “Without such capabilities, manufacturers risk situations such as when cumin spice manufacturers found ground peanut shells in what they believed to be 100% cumin (the inferior ground peanut shell ingredient was used to increase yield and charge the higher cumin price tag [a form of economic adulteration] and unfortunately also resulted in allergen contamination.”

Based in the US, Neumann has watched closely as FSMA has affected the allergen control landscape there, adding more rigor to food facilities’ allergen management systems. For her allergen management is no longer only a GMP (good manufacturing practice) requirement. “FSMA has elevated the importance of allergen control in the US to the highest level of required food safety control — namely, a preventive control. This means that if an allergen preventive control is implemented and fails, the product is presumed not to be food safe, and a role specifically trained in food safety and this regulation (a preventive control qualified individual-PCQI) must evaluate the product for safety prior to its release/distribution.”

“FSMA has elevated the importance of allergen control in the US to the highest level of required food safety control — namely, a preventive control”

Having worked with many brands to help them improve their industry practices, she’s all too aware of the damage an allergen incident can do to a brand’s reputation. “The more common result,” she explains, “is a product recall that could span multiple products and production days, resulting in substantial financial, reputational, and business risk in addition to the regulatory risk associated with a recall. But there is always the danger of a worst-case scenario - the death of an allergic consumer from anaphylactic shock.”

So as new regulations like FSMA evolve the food allergen control landscape, what industry changes would she like to see implemented to make food safer for consumers? Her answer is simple - increased traceability to produce a more visible and transparent supply chain. She says, “There are too many ‘black holes’ as I call them - gaps in food facilities’ understanding of where their ingredients truly come from. This became clear when FSMA required food facilities to implement supply chain applied controls and conduct supplier verification activities. Many facilities stop this supplier verification process at the immediate previous supplier. But is that the source supplier? Or did that supplier purchase ingredients from a different supplier even further upstream?”

“There are too many ‘black holes’ as I call them - gaps in food facilities’ understanding of where their ingredients truly come from”

She believes that many facilities still do not know the answer and hopes that enhanced traceability systems will help shed light on these black holes. To make that possible a larger education piece is necessary to connect the impact of traceability to the financial health of a business – and this is the key to driving through change.

“I would like to see greater education in food safety risk communications between food safety professionals and their C-Suites so that food safety investments are being made appropriately and are tied to the company’s enterprise risk management strategy."

We dig deeper into how the upcoming regulations are shaping the food industry's traceability journey in our new report on the subject. Download your copy to get all the insights.