1.
Food Safety
ASB Presentation May 2015
Alison Wright
Director Quality Assurance Asia Pacific
Food safety systems and compliance
A focus on
undelcared allergens

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 Between 1 Jan 2005 and 31 Dec 2014, FSANZ was notified of 586 recalls.
The average number of recalls per year for the last 10 years is 59 recalls.
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FOOD RECALLS AUSTRALIA
2014 Top 3:
1. Undeclared Allergens
(Labelling)
2. Microbial
Contamination
3. Foreign Matter

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Undeclared Allergens:
Peanuts 21%
Dairy 17%
Wheat 16%
Product Categories:
Processed Foods 33%
Confectionary 18%
Bakery 15%
FOOD RECALLS AUSTRALIA
Undeclared Allergens – broken down

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FoodStandardsCode
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Why do we need Food labels?
Food labels provide information to help us make choices.
Labels do the following:
• Tell us which nutrients, in what amounts, are in a product
• Warn us if a food contains food allergens
• Inform us if the food is fresh or out of date
• When necessary, explain how to store, prepare or cook the food we buy
• List product ingredients
• Give us information on where the food was produced and which
company has marketed it
Essentially, food labels are there to provide us with basic information
about what is in the food we eat and how best to handle it.
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Mandatory declaration of certain substances in food
(1) The presence in a food of any of the substances listed in the Table to this clause, must be
declared in accordance with subclause (2), when present as –
(a) an ingredient; or
(b) an ingredient of a compound ingredient; or
(c) a food additive or component of a food additive; or
(d) a processing aid or component of a processing aid.
(2) The presence of the substances listed in the Table to this clause must be –
(a) declared on the label on a package of the food; or
(b) where the food is not required to bear a label pursuant to clause 2 of Standard 1.2.1 –
(i) declared on or in connection with the display of the food; or
(ii) declared to the purchaser upon request; or
(c) displayed on or in connection with food dispensed from a vending machine.
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Allergen, advisory and warning statements

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 Added Sulphites in concentrations of 10 mg/kg or more
 Cereals containing gluten and their products, namely, wheat, rye, barley, oats
and spelt and their hybridised strains other than where these substances
are present in beer and spirits standardised in Standards 2.7.2 and 2.7.5
respectively
 Crustacea and their products
 Egg and egg products
 Fish and fish products, except for isinglass derived from swim bladders and
used as a clarifying agent in beer and wine
 Milk and milk products
 Peanuts and peanut products
 Sesame seeds and sesame seed products
 Soybeans and soybean products
 Tree nuts and tree nut products other than coconut from the fruit of the
palm Cocos nucifera
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Mandatory Allergen Warning Statements

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Where do I start?

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Where do I start?
1. What products am I going to be manufacturing, handling, storing, or
distributing?
2. What country am I manufacturing in?
3. What country am I going to be selling my products in?
4. What does legislation require?
In the country of manufacture and sale?
5. What do my customers require?
Do they have any special requirements?
What audit standards do I need to meet?
6. Am I going to make any allergen claims?
Dairy Free, Gluten Free, Nut Free
7. What is considered reasonable precaution? Due Diligence

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Where do I start?
8. Formulation Details
 What known allergen’s am I going to need to list…
9. Raw Material Specification Details & the hidden allergens
 Did I get a basic specification or an AFGC PIF?
 Is my supplier the manufacturer or the broker?
 an ingredient of a compound ingredient; (baking powder with wheat flour)
 a food additive or component of a food additive; (soy lecithin)
 a processing aid or component of a processing aid (soy antioxidant)
 What not so obvious allergen’s am I going to need to list…
10. Processing Details
 Ingredients used in the facility
 Ingredients used on the line
 Ingredients stored with
 Ingredients dispatched with
 What known allergen’s am I going to need to list…

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My checklist…
Do I really know what I am doing?
What tools have I got to use to help?
What industry help can I get?
Who can I talk to if needed?
 FSANZ Legislation http://www.foodstandards.gov.au
 Allergen Bureau http://allergenbureau.net
VITAL (Voluntary Incidental Trace Allergen Labelling) Program
 Allergy & Anaphylaxis Australia http://allergyfacts.org.au
 AFGC (Australian Food & Grocery Council) http://www.afgc.org.au

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What does a GOOD example look like?
13Source: AFGC

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Precautionary Statements
* may contain / * may be present
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VITAL
Industry standard:
If you have used VITAL assessment
statement should read
“may be present”
• Ingredients or Processing
Impact?
• Particulate form?
• Readily dispersible?
• Action levels 1,2 ?
 Labelling guidance provided..

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And what really happens in the plant?......
Is it controlled?
Do people do
everything they have
been instructed or
trained to do?

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The Checklist….
Business
Commitment
• Food Safety Leaders should explain the impact of
legislation & customer requirements to senior
management.
• Allergen Management may need to be included
into capital planning.
• Company Awareness.
• Site Induction.

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The Checklist….
Product
Development
• Review the customers’ requirements & potential
claims required. Complete in conjunction with your
business ‘Allergen Expert’ & Allergen Policy.
• Review potential allergens, sensitivities & emerging
issues and trends.
• Review where the product will be sold and market
requirements/restrictions.
• Only add new allergens to products when they make a
noted difference in the taste or functionality of the
product.
• Review primary & secondary level raw ingredients –
where was the ingredient was derived from?
• Check ingredients specification & label compliance.

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The Checklist…..
Manufacturing
• Raw material Storage.
• Raw material Transfer / Handling / Use – controls.
• Raw Product Specifications / PIF’s. - control.
• Formulation Control.
• Product Scheduling / Product Change Over.
• Cleaning & Sanitation & Allergen Spills.
• Validation and verification plans. (& VITAL)
• Internal audit.
• Specification and Label reviews.
• Site Policy – lunchrooms, vending machines.
• Train, train & re-train & have a good competency based
assessment!

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The Checklist…..
• Storage of products.
• Product identification & protection.
• Cleaning & Sanitation.
• Allergen Spills.
• Include in internal audits.
• Training of staff.
Warehousing /
Distribution

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The Checklist…..
• Allergen policy
• Vendor Assurance Program
• Risk assessment procedure
• Work instructions and procedures
• Ongoing validation of controls
• Cross referencing into HACCP system
Support
Programs

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The Checklist…..
• Validation
• Verification
• Where to start?
• Experimental Design?
Validation &
Verification

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The Checklist…..
• Review the total process
• Ongoing review should occur within internal audits,
however needs to be specific & detailed for Allergens.
• Ongoing training.
• Has anything changed, shifted, moved?
Ongoing Review

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HOT TIPS #1 . .
 A Food Safety Plan, based on HACCP should be used to assess
Allergen Management.
 Use dedicated tools & equipment, and color coded where possible,
clearly labeled & identified for allergen to non-allergen production
runs. Included engineers complete tool box set.
 Use different colored outer clothing including hairnets, gloves, etc
are to be worn to ensure no risk of cross contact.
 Schedule longer runs of allergen products to reduce downtime,
costs of cleaning, validation & verification activities.
 Validation plans should occur on worst case scenario to ensure
effectiveness.

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HOT TIPS # 2 . .
 Cleaning is not to remove bacteria. The Allergenic Protein can be
more difficult to remove than bacteria. Specific ‘cleaning
methodology’ may be required.
 Ensure test methods suit the objective, including product matrix
(cooked/uncooked product), LOD (Limit of Detection), test error
and legislation or limit compliance required.
 Swabbing plans – both food contact and non-contact areas.
 Vendor Assurance – Supplier Allergen Management Systems &
“ingredients derived from”.
 Ensure Air handling and filtering system are included into the
assessments.
 Seek industry leaders to consult with on your specific
project/activities

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Due Diligence
Are your systems
going to protect you…
Should your
business be challenged?
Allergen Control
is all about protecting the
consumer from
potential food related
reactions….

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Thank-you Alison Wright - ARYZTA - Director Quality Assurance Asia Pacific