Nov 22, 2022 : Yesterday, Food Safety News reported that the "FDA sends warning to food firm in Chicago over violations at their bakery facility".
This story is interesting and instructive. Food Safety is a key concern for all of us in the food industry and reading about failures that occurred at another company, helps us learn and get better at ensuring food safety.
This is a particularly unusual situation in that the company clearly had a food safety plan, and oddly enough even identified the potential risk. The head scratching question is why it was discounted so easily given the potential for harm and financial consequences for the company.
In short, the FDA found that "The firm’s hazard analysis considered undeclared allergens at the packaging/labeling step, but determined that this hazard was not “Significant” (i.e., did not require a preventive control) because “[a]ll products contain wheat, milk, egg and soy which are known allergens. Products containing nuts or coconut, contain a unique allergen, tree nuts".
First, this is clearly a significant hazard (mis labeling and/or allergen cross contact). Secondly, because it was considered "not significant", basic controls such as ensuring segregation of ingredients, and running the line with least allergens to most was ignored. Honestly these are simple and "free" controls - running the line with product A with less allergens and then product B, is simply a scheduling issue, and adds zero cost.
In instances where there are multiple variants of a particular product, (especially so when some have unique allergens), ensuring that the correct label is applied is critical, and honestly, its not too complicated to do (ensuring segregation of product variations and QA-ing to ensure the right label was applied).
The impacts of these kind of breakdowns are especially potentially lethal to consumers with food allergies, and can impact the consumer's trust in labeling, and in our industry.
The rest of the letter is a good read, it includes breakdowns in labeling, inventory storage, exposure to environmental pathogens, lack of supplier controls etc.