FSIS Takes “Notice” Regarding Preventing Allergen Recalls

This summer, the U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) issued a Notice (35-11) in response to an increase in recalls due to undeclared allergens in meat and poultry products. FSIS also hosted a webinar and posted associated materials on its website, available by clicking here.

Even after FSIS issued this Notice and hosted the webinar for industry, there have been over thirty additional allergen recalls of meat and poultry products since last July. The primary causes of these recalls have been identified as:

  • The incoming ingredients were reformulated or changed but the label was not updated;
  • Establishments simply used wrong labels; and
  • Establishments reformulated products but failed to change the labels.

Establishments have the responsibility to properly label all ingredients. There is a particular concern regarding allergens due to the potential health impact for some consumers. Establishments should consider these ingredients in their hazard analysis and have an allergen control plan. A few tips for ensuring success in preventing an undeclared allergen recall include:

  • Reviewing the current label stock and discarding old labels. If the old labels are not available in inventory – they will not be used by mistake;
  • Maintain good communication with ingredient suppliers. Make sure you are notified if they make changes to any of their ingredients;
  • Have procedures in place to review the labels of purchased ingredients to ensure they are consistent with ingredient specifications;
  • Ensure that any “may contain” statements have been carried through from incoming ingredients to final labels;
  • Restrict label and ingredient access to appropriate personnel; and
  • Monitor/verify – conduct periodic audits.

It is critical that the product bears the appropriate label and that the ingredients in the product match the ingredients on the label. This is key to ensuring that the product is properly labeled.

We hope this information is helpful in ensuring that you are successful in implementing your allergen control plan.

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