Baking & Snack - May 2018 - 28


The ongoing allergen battle
According to the Food and Drug Administration (FDA)'s
Reportable Food Registry, allergen control is a continuous issue for baking and snack companies. In January,
FDA published its final Preventive Controls for Human
Food rule, which requires preventive controls for food allergens. It also updated its Good Manufacturing Practices
guidelines to prevent allergen cross-contact.
"Whether bakery or snack producers, they all face incredible exposure from a regulatory focus on undeclared
allergens," said Shawn Stevens, founder, Food Industry
Counsel. "They need to get programs in place to address
this head-on." This allergen control program should be
found in the company's written preventive control program as well as its Foreign Supplier Verification Program,
if applicable, and could include actions such as label supplier oversight, management of incoming raw materials,
management of ingredients and label reviews.
Although companies should already be preventing
cross-contact through sanitation controls and product
sequencing, allergen control also includes labeling. This allergen labeling is one part of the Nutrition Facts label rule,
FSMA's next major regulation with compliance deadlines
starting in January 2020.
According to the FDA Food Labeling Guide, "major
food allergens" account for 90% of all food allergies and
include milk, egg, fish, crustacean shellfish, tree nuts,
wheat, peanuts and soybeans. With the Nutrition Facts label rule, companies comply with the allergen control section by declaring these major allergens on food labels in
two forms: adding the common name of the major food
allergen in parenthesis after its scientific name in the list
of ingredients or placing the word "contains" followed
by the major food allergens after the list of ingredients.
"It takes a long time to review and revise labels," said
Russell Statman, executive director, Registrar Corp.
"Don't wait until 2019. If you haven't started yet, get
started now."

address; instead, it inspects through a review of records.
It's essential that importers have an FSVP plan that details the process for verifying supplier compliance and
includes the proper documentation. Since FSMA is not
prescriptive, this can be done in a variety of ways.
To collect approval documentation, the FSVP importer can conduct a hazard analysis of the product, or
the foreign supplier can conduct the analysis and get
it assessed and signed by the importer. The person responsible should also review the compliance history of
the supplier by checking supplier visits on FDA's website
and verifying the company's consent to its own country's
regulations. Additional actions could include sampling
and testing, an AIB inspection, and onsite auditing every
few years or annually, depending on the supplier's performance and risk level of the product being imported.
Some food manufacturers might not have the resources to visit their foreign suppliers yearly or even every two
years. Mr. Heflich suggested being creative, which could
mean getting the supplier GFSI-certified or receiving
pictures and videos of processing plants. When it comes
to this regulation, the more records, the better.
Communication is critical. FSVP importers need to
explain the regulations to their suppliers and receive
updates from them. Due to the qualification issue, some
foreign vendors should check on their FSVP importers
in the US by verifying their knowledge and plan and by
being proactive in sending required documents. AIB has
created presentations to help foreign suppliers understand the regulations and fill in gaps for them. Bakery
and snack producers should also create a detailed supplier food safety plan and review it with their importers.
To prepare for compliance, General Mills, Minneapolis,
performed a gap assessment for its program against the
FSVP rule and evaluated the company's cooperation
with PCHF. "We also performed a mock audit against
the FSVP requirements to test our system," said Bridget
Christenson, media relations manager, General Mills.
"The mock audit was an invaluable exercise and taught us
a lot about the strength of our program."
General Mills created a Supplier Code of Conduct for
US and foreign companies. Its four pillars of responsibility include human rights, health and safety, environment
and business integrity. The company also incorporated
a section about compliance, which identifies high standards for suppliers and how conflicts will be addressed.
Ms. Christenson encouraged companies to contact
the Food Safety Preventive Controls Alliance (FSPCA),
a cooperation between FDA and the Illinois Institute of
Technology's Institute for Food Safety and Health, which
Clear communication between an importer and supplier, company and importer,
and supplier and its employees is necessary with FSVP.
AIB International

28 Baking & Snack May 2018 /

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