Late last year, the FDA warned two major US firms for ‘repeat offenses’ of product labels not specifying allergens. Two letters do not constitute a trend, but I was reminded of these incidents recently, as I read our monthly intelligence reports.
Astonishingly, in the period July 2020 to January 2021, nearly half of the recalls in our monitored markets were down to mislabeling of allergens. In December, that figure topped 70%.
This is data that cuts across some of our most sophisticated and robust markets and nobody can argue that food companies aren’t aware of or attuned to the scale of risk that allergen mislabeling carries. So why does this keep happening? And more important for everyone concerned – especially the consumer – what can be done to fix the problem?
My money is on three factors being the root cause.
First, supply chain disruption. It is easy to underestimate just how disruptive COVID-19 has been to food security and supply chains. When so many firms have had to manage frequent and urgent changes to ingredient suppliers, a failure to ask the right questions and take the time to assess substitution in products is an inevitable risk. Understanding and verifying the equivalence of any alternative product in your supply is essential – but will not have been easy in 2020.
Second, label approval processes. Because food safety standards require manufacturers to review labels annually and in the event of change, most businesses have well-established processes place. But when were those processes last updated or challenged? And is the right expertise in place to do so? A process that worked well in the past is no guarantee of a process that’s fit for the future and the data suggests that we urgently need to delve deeper into label approval, review and control processes themselves, if our obligations to the consumer are to be met.
Finally, production environment controls. Staff shortages, remote working and a shopping list of COVID-inspired changes to working practices will have proved particularly challenging in manufacturing environments in the past 12 months. This is a perfect environment for lapses in production controls to emerge. Whether monitoring product and packaging changeover or examining cross contamination prevention protocols, now is the time to challenge and test these practices.
Failure to recognize that something in the supply chain has changed or been disrupted is the single biggest food safety risk that any organization faces – large or small. Consumers are more reliant than ever on the accuracy of this information and as the FDA case shows, companies are more exposed than ever to the associated legal and regulatory risks.
The data makes for sobering reading. We need to step up.
Find out more about how LRQA can help with our Labeling advisory services.
