Food Safety

ASB Presentation May 2015

Alison Wright

Director Quality Assurance Asia Pacific

Food safety systems and compliance A focus on undelcared allergens

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Between 1 Jan 2005 and 31 Dec 2014, FSANZ was notified of 586 recalls.

The average number of recalls per year for the last 10 years is 59 recalls.

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FOOD RECALLS AUSTRALIA

2014 Top 3: 1. Undeclared Allergens

(Labelling) 2. Microbial

Contamination 3. Foreign Matter

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Undeclared Allergens: Peanuts 21% Dairy 17% Wheat 16%

Product Categories: Processed Foods 33% Confectionary 18% Bakery 15%

FOOD RECALLS AUSTRALIA Undeclared Allergens – broken down

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Why do we need Food labels?

Food labels provide information to help us make choices.

Labels do the following:

• Tell us which nutrients, in what amounts, are in a product

• Warn us if a food contains food allergens

• Inform us if the food is fresh or out of date

• When necessary, explain how to store, prepare or cook the food we buy

• List product ingredients

• Give us information on where the food was produced and which

company has marketed it

Essentially, food labels are there to provide us with basic information about what is in the food we eat and how best to handle it.

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Mandatory declaration of certain substances in food (1) The presence in a food of any of the substances listed in the Table to this clause, must be declared in accordance with subclause (2), when present as – (a) an ingredient; or (b) an ingredient of a compound ingredient; or (c) a food additive or component of a food additive; or (d) a processing aid or component of a processing aid. (2) The presence of the substances listed in the Table to this clause must be – (a) declared on the label on a package of the food; or (b) where the food is not required to bear a label pursuant to clause 2 of Standard 1.2.1 – (i) declared on or in connection with the display of the food; or (ii) declared to the purchaser upon request; or (c) displayed on or in connection with food dispensed from a vending machine.

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Allergen, advisory and warning statements

Added Sulphites in concentrations of 10 mg/kg or more

Cereals containing gluten and their products, namely, wheat, rye, barley, oats and spelt and their hybridised strains other than where these substances are present in beer and spirits standardised in Standards 2.7.2 and 2.7.5 respectively

Crustacea and their products

Egg and egg products

Fish and fish products, except for isinglass derived from swim bladders and used as a clarifying agent in beer and wine

Milk and milk products

Peanuts and peanut products

Sesame seeds and sesame seed products

Soybeans and soybean products

Tree nuts and tree nut products other than coconut from the fruit of the palm Cocos nucifera

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Mandatory Allergen Warning Statements

Where do I start?

Where do I start?

1. What products am I going to be manufacturing, handling, storing, or

distributing?

2. What country am I manufacturing in?

3. What country am I going to be selling my products in?

4. What does legislation require?

In the country of manufacture and sale?

5. What do my customers require?

Do they have any special requirements?

What audit standards do I need to meet?

6. Am I going to make any allergen claims?

Dairy Free, Gluten Free, Nut Free

7. What is considered reasonable precaution? Due Diligence

Where do I start?

8. Formulation Details

What known allergen’s am I going to need to list…

9. Raw Material Specification Details & the hidden allergens

Did I get a basic specification or an AFGC PIF? Is my supplier the manufacturer or the broker? an ingredient of a compound ingredient; (baking powder with wheat flour) a food additive or component of a food additive; (soy lecithin) a processing aid or component of a processing aid (soy antioxidant) What not so obvious allergen’s am I going to need to list…

10. Processing Details

Ingredients used in the facility Ingredients used on the line Ingredients stored with Ingredients dispatched with What known allergen’s am I going to need to list…

My checklist…

Do I really know what I am doing?

What tools have I got to use to help?

What industry help can I get?

Who can I talk to if needed?

FSANZ Legislation http://www.foodstandards.gov.au

Allergen Bureau http://allergenbureau.net

VITAL (Voluntary Incidental Trace Allergen Labelling) Program

Allergy & Anaphylaxis Australia http://allergyfacts.org.au

AFGC (Australian Food & Grocery Council) http://www.afgc.org.au

What does a GOOD example look like?

13 Source: AFGC

Precautionary Statements

* may contain / * may be present

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VITAL Industry standard: If you have used VITAL assessment statement should read “may be present” • Ingredients or Processing

Impact? • Particulate form? • Readily dispersible? • Action levels 1,2 ?

Labelling guidance provided..

And what really happens in the plant?......

Is it controlled?

Do people do everything they have been instructed or trained to do?

The Checklist….

Business Commitment

• Food Safety Leaders should explain the impact of legislation & customer requirements to senior management.

• Allergen Management may need to be included into capital planning.

• Company Awareness.

• Site Induction.

The Checklist….

Product Development

• Review the customers’ requirements & potential claims required. Complete in conjunction with your business ‘Allergen Expert’ & Allergen Policy.

• Review potential allergens, sensitivities & emerging issues and trends.

• Review where the product will be sold and market requirements/restrictions.

• Only add new allergens to products when they make a noted difference in the taste or functionality of the product.

• Review primary & secondary level raw ingredients – where was the ingredient was derived from?

• Check ingredients specification & label compliance.

The Checklist…..

Manufacturing

• Raw material Storage.

• Raw material Transfer / Handling / Use – controls.

• Raw Product Specifications / PIF’s. - control.

• Formulation Control.

• Product Scheduling / Product Change Over.

• Cleaning & Sanitation & Allergen Spills.

• Validation and verification plans. (& VITAL)

• Internal audit.

• Specification and Label reviews.

• Site Policy – lunchrooms, vending machines.

• Train, train & re-train & have a good competency based assessment!

The Checklist…..

• Storage of products.

• Product identification & protection.

• Cleaning & Sanitation.

• Allergen Spills.

• Include in internal audits.

• Training of staff.

Warehousing / Distribution

The Checklist…..

• Allergen policy

• Vendor Assurance Program

• Risk assessment procedure

• Work instructions and procedures

• Ongoing validation of controls

• Cross referencing into HACCP system

Support

Programs

The Checklist…..

• Validation

• Verification

• Where to start?

• Experimental Design?

Validation &

Verification

The Checklist…..

• Review the total process

• Ongoing review should occur within internal audits,

however needs to be specific & detailed for Allergens.

• Ongoing training.

• Has anything changed, shifted, moved?

Ongoing Review

HOT TIPS #1 . .

A Food Safety Plan, based on HACCP should be used to assess

Allergen Management.

Use dedicated tools & equipment, and color coded where possible,

clearly labeled & identified for allergen to non-allergen production

runs. Included engineers complete tool box set.

Use different colored outer clothing including hairnets, gloves, etc

are to be worn to ensure no risk of cross contact.

Schedule longer runs of allergen products to reduce downtime,

costs of cleaning, validation & verification activities.

Validation plans should occur on worst case scenario to ensure

effectiveness.

HOT TIPS # 2 . .

Cleaning is not to remove bacteria. The Allergenic Protein can be

more difficult to remove than bacteria. Specific ‘cleaning

methodology’ may be required.

Ensure test methods suit the objective, including product matrix

(cooked/uncooked product), LOD (Limit of Detection), test error

and legislation or limit compliance required.

Swabbing plans – both food contact and non-contact areas.

Vendor Assurance – Supplier Allergen Management Systems &

“ingredients derived from”.

Ensure Air handling and filtering system are included into the

assessments.

Seek industry leaders to consult with on your specific

project/activities

Due Diligence

Are your systems

going to protect you…

Should your

business be challenged?

Allergen Control

is all about protecting the

consumer from

potential food related

reactions….

Thank-you Alison Wright - ARYZTA - Director Quality Assurance Asia Pacific