Food Allergens as Chemical Hazards

Food allergens have become increasingly important to food processors because they can represent a serious health hazard. It is estimated that 2 per cent of the Canadian population are affected by life-threatening allergies and the number is increasing, especially in children. While this figure may not seem significant at first glance, it represents about 600,000 people (Health Canada).

Why are Food Allergens Important?

An allergic reaction occurs when the immune system reacts to a particular allergen. Proteins are allergen agents that cannot be eliminated during cooking, and trigger an allergic reaction. Organs usually affected by an allergic reaction are: the skin and the respiratory, gastrointestinal and cardiovascular systems. There is no cure for food allergies. Research is being done to develop vaccines against severe allergic reactions. Avoidance of foods causing allergic reactions is the only way to prevent them. Food processors must ensure that food products are not contaminated with potential allergens not listed on their labels.

What are Food Allergens?

Health Canada has prioritized ten food allergens:

• eggs
• seafood (fish, crustaceans, shellfish)                         
• milk
• mustard
• peanuts
• sesame seeds
• soy
• sulphites (food additives including: potassium bisulphite/metabisulphite, sodium bisulphite/dithionite/metabisulphite/sulphites, sulfur dioxide, sulphiting agents, sulphurous acid)
• tree nuts (almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pinenuts,  pistachios, walnuts)
• wheat and triticale

How to Control Food Allergens in your Facility?

An allergen management/control program is an effective tool to avoid unintentional allergen cross-contamination of food products, to prevent food recalls and to protect consumers. The implementation of a control program will depend on the size and specific factors of your facility.

Essential steps in developing an effective allergen management program include:

Allergen Assessment

Allergens should be considered as a part of the hazard analysis of any operation. Food facilities require a master list of all ingredients and raw materials used. This list should also include:  food additives, spices, flavors and colorings. Identify if the raw materials or ingredients contain an allergen from the known group of food allergens (PDF 370KB). Clearly indicate on your list, those ingredients that are, or contain allergens and require special measures.

Supplier Information

Food processors should obtain ingredient specification sheets, certificates of analysis or a complete list of ingredients. Ask if your supplier has a documented allergen control program in place. When buying ingredients, a letter that guarantees that ingredients are free of undeclared allergens should accompany your materials.

Shipping, Receiving, Handling and Storage

Ingredients containing allergens should be shipped in properly labelled and sealed containers, and physically separated from allergen-free ingredients. Receiving employees should inspect the shipments for spills or damaged containers. Allergenic food ingredients should be stored separately from other ingredients. If not possible, a distance of about 1.5 meters should be maintained between allergens and other ingredients. Store allergenic raw materials on the bottom of racks to avoid accidental spills on items below them. Identify raw materials with an “Allergen” and/or a color-coded tag. For more information, visit the shipping, receiving, handling and storage page.

Production and Plant Scheduling

Allergens can be controlled within a food processing plant during production. If possible, use equipment, employees and production lines only for allergenic products. If this is not feasible, an alternative for controlling product cross-contamination is to schedule the production of products containing allergens at specific periods.

Examples of production scheduling alternatives include:

• Plan the production of long runs of products free of the common allergens to minimize changes in your production lines.
• Products containing allergens could be produced on specific days of the week.
• Allergen-containing products should be produced as the last product on the line.

Product Flow

Evaluate the product flow during your production cycle. Cross-contamination of products can occur if products containing an allergen are placed on conveyors that cross over allergen-free products. This can unintentionally expose and contaminate allergen-free products. 

Packaging

Food packaging materials should be stored in designated areas to avoid allergen cross-contamination. Packaging materials should be suitable for allergen-free food products. For example, do not use foil coated with wheat ingredients for a wheat-free product. 

Labelling

Labelling is critical for foods containing allergens. Label accuracy should be confirmed against the product’s declared ingredients. Misleading information can cause: consumer health problems, product recalls and even death. The Canadian Food Inspection Agency (CFIA) enforces Canada’s labelling laws to ensure complete, accurate labelling of all foods. A Guide to Food Labelling and Advertising - List of ingredients is available from the CFIA website. 

• Common terms for food allergens (e.g., milk and not casein) are strongly recommended for use on food labels. The federal government has also developed a precautionary allergen labelling policy (e.g., "may contain peanuts”). This policy allows for the voluntary labelling of products that may inadvertently contain allergens. This blanket statement should not be a substitute for Good Manufacturing Practices (GMPs) in your facility. 
• However, Health Canada is now modifying the Food and Drug Regulations to ensure that the most common food components that cause severe allergic reactions are on food labels. For more information of food labelling visit the Food Labelling and Allergen Control page.

Cleaning and Sanitizing

Equipment should be inspected for the presence of allergens before the production of a new product begins. If equipment is shared for the manufacture of allergen-free foods and allergenic foods, a Sanitation Standard Operating Procedure (SSOP) should describe in detail the cleaning and sanitation procedure. Allergen test kits are recommended to assess the effectiveness of cleaning. Attention should be given to equipment that is in contact with food containing allergens. For instance, a conveyor that moves food can lead to allergen contamination. Conveyor belts are difficult to clean and sanitize, especially hidden surfaces such as hinge points. Industry experts advise that plastic belts are more easily contaminated than stainless steel belts. You must ensure that an effective cleaning program is in place. 

Documentation

All activities that carry out and verify your program is working need to be documented. Records are important to demonstrate that your facility is taking adequate measures to control possible allergen cross-contamination. These are especially important if there is a recall or an audit. An allergen check list for food suppliers and manufacturers is available from the CFIA website and can be useful for your records. Results of allergen tests conducted in your facility can also form part of your records.   

Employee Training

Employees need to understand the consequences of allergens to consumers, as well as the financial consequences of a product recall. Provide adequate training so employees are familiar with the groups of food allergens, the importance of adequate product labelling, cleaning sanitizing and storage. 

Program Evaluation

Frequently evaluate the effectiveness of your allergen control program. Routine auditing of your plant operations is important to verify that the program is working. 

One of the most frequent recalls is for undeclared food allergens in a product. The cost of a product recall can be as much as five times the distribution cost of the product. Furthermore, the brand name may suffer irreparable damage. If a food product contains allergens not indicated on the label, the CFIA can take corrective measures by recalling the product. CFIA provides advice to the food industry to reduce food product recalls. Information for managing allergen risks in food products is available through the CFIA website. There many recalls due to the presence of undeclared allergens in foods. 

These are some examples of non-intended situations where allergens can be present in food products and result in food safety issues: 

• products containing an allergen not indicated on the label
• products contaminated with an allergen when no appropriate controls are taken (e.g., allergens due to the use of common equipment)
• products containing food additives, flavor or spices that are allergens but are not indicated on the ingredient list provided by your supplier

Testing for allergen residues after cleaning and sanitizing operations can help verify cleaning procedures. It can also help prevent allergen cross-contamination of food products. Analytical laboratories can provide help in developing an allergen testing program. There are also several commercial enzyme-linked immunosorbent assays (ELISA) kits to test for food allergens available on the market. Surface swabs can be used by employees to detect the presence of allergens on food contact surfaces.

• CFIA - Food Labelling Requirements Checklist
• CFIA - Food Allergen Labelling
• Health Canada - Food Allergen Labelling
• Food Safety Testing
• Food Labelling and Allergen Control

 
For more information, email the Food Safety and Inspection Branch or call 204-795-8418 in Winnipeg.

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