Roughly 220 million people around the world have a food allergy of some kind. Consumers dealing with these allergies place their trust in food and beverage (F&B) manufacturing facilities to create products that are safe for consumption or clearly labeled with allergen warnings. That trust makes avoiding allergen cross-contact essential for every F&B facility and a top priority under FDA guidance and FSMA guidelines.
For your team, the first step in preventing food safety incidents is understanding the severity of this potential hazard and how to avoid it. Educating your team on the implications and proper prevention of allergen cross-contact will help maintain compliance and ensure the safety of your consumers.
Cross-Contact Definition: What is allergen cross-contact?
Allergen cross-contact occurs when a major food allergen is unintentionally spread from one food product to another that does not contain it. This can occur either directly, through two food products coming into contact with each other, or indirectly, through shared machinery, inadequate cleaning procedures, or improper ingredient handling. The accidental cross-contact of allergens can also happen at any point in the food manufacturing process.
Cross-Contamination vs Cross-Contact
Although the terms sound similar, there are several key distinctions between the definitions of cross-contact and cross-contamination.
Both processes involve the spread of dangerous hazards across food products. However, cross-contamination refers to the transfer of bacteria or viruses between food products, which can result in foodborne illnesses. The definition of cross-contact, on the other hand, refers to the transfer of allergens.
Additionally, it’s important to note that pathogenic microorganisms can be killed by cooking foods to a safe internal temperature, whereas allergen proteins cannot. Both hazards are potentially dangerous to consumers, making it all the more imperative that your team prevent both.
Allergen Cross-Contact Risks
Cross-contact poses a variety of legal, regulatory, and physical risks that can lead to severe cumulative consequences for both your facility and your consumers. Keep these risks in mind when designing your food safety plan and educate your employees on why allergen cross-contact should be a top concern:
- Inaccurate labeling: When allergens are introduced to a product accidentally, the product label can’t reflect the presence of unknown ingredients. As such, allergen cross-contact can void the accuracy of your food product's allergen labels, which not only leads to noncompliance but also puts consumers at risk of unknowingly buying products that could harm them.
- Allergic reactions: Consumers who unknowingly purchase products containing allergens are at physical risk of an allergic reaction. These accidental reactions can range in severity from mild to life-threatening, so even one allergic reaction can lead to severe repercussions for consumers and your facility.
- Recalls: Once an allergic reaction due to a non-labeled allergen is discovered, a recall will be issued, which can have significant adverse (sometimes irreversible) effects on your brand perception as well as significantly impact your bottom line with its associated costs.
- Legal recourse: Beyond disciplinary actions from the FDA, you may also face legal repercussions from consumers affected by the allergen cross-contact. Legal action can not only cost your facility financially, but it can also become a permanent stain on your reputation.
Common Causes of Allergen Cross-Contact and How to Avoid Them
Even the smallest trace of an allergen (present in a product where it shouldn’t be) is a hazard that can have significant consequences. If your facility handles allergens in any capacity, your team must take proactive steps to prevent common causes of cross-contact and protect consumers from unforeseen dangers.
Ineffective Allergen Controls
The FDA’s Food Safety Modernization Act (FSMA) requires facilities to implement preventive controls to avoid hazards, including allergen cross-contact. But even with controls in place, they can fall short — such as when cleaning procedures aren’t validated for allergens, staff aren’t consistently training on proper allergen handling, or allergen removal isn’t verified through routine testing.
Solution: Develop an effective allergen control plan.
Avoiding a lapse in food safety requires a framework of clear, written food allergen controls for your team to follow. These can include steps such as:
- Equipment management
- Sanitation schedules
- Equipment design
- Ingredient controls
- Recordkeeping procedures
- Allergen verification testing
- Label review and validation
These controls function as a blueprint for your everyday operations and set the foundation for the rest of your allergen cross-contact prevention efforts. Incorporating allergen-specific surface testing, such as rapid test strips or PCR testing, helps validate that your sanitation procedures are truly effective.
After developing and implementing your allergen control plan, employee training and education are critical. For allergen controls to work effectively, your team must understand how to implement them, monitor outcomes, and respond appropriately in the event of a potential issue.
Inadequate Cleaning of Shared Equipment
Part of effective cross-contact prevention is the proper cleaning and sanitation of shared machinery and equipment. Inadequate cleaning of a machine can cause allergen cross-contact across an entire batch of product — leading to a significant breach in food safety.
Solution: Implement a comprehensive sanitation plan.
Part of your food safety plan development should include clearly outlining proper sanitation processes, including:
- Sanitation schedules
- Standardized procedures
- Process documentation
- Tool and supply lists
This plan should be closely followed and deeply understood by your employees to minimize the potential risk of cross-contact caused by poor sanitation.
Improper Segregation of Allergens
Producing food products that contain allergens in the same facility as products that don't carries an inherent risk of allergen cross-contact. Still, there are steps you can take to ensure segregation of allergens during production.
Solution: Incorporate allergen segregation measures in your facility and process design.
Your facility’s layout will determine how well you can segregate allergens. While having a completely separate facility for each allergen you handle might be ideal, it’s not necessarily practical. Instead, you can dedicate specific spaces or production areas in your facility to certain major allergens, separating them into distinct areas to lower the risk of spread.
You can also schedule production runs and sanitation schedules to maximize segregation. For example, you can reserve using a line for allergen-laden production until the end of a production run — sanitizing equipment thoroughly after its use.
Unsuitable Rework Process
Reworking unused food products may be an excellent way to minimize food waste, but this process can be fraught with allergen cross-contact risk. Whether it be through improper handling or inadvertently mixing allergenic products into non-allergenic products, facilities that don't take proper precautionary measures during their rework process can risk unintentionally spreading allergens.
Solution: Establish effective rework processes.
Rework processes should be approached with the same caution as standard production. The allergen controls you established in your food safety plan must encompass this part of your production process, providing clear instructions on how to avoid cross-contact during rework.
Outline sanitation practices, segregation practices, and personal hygiene standards specific to this process. The more comprehensive your rework procedures are, the more likely you are to avoid common risks associated with allergen cross-contact.
Evaluate your allergen controls with AIB International
Preventing allergen cross-contact requires a dedication to following proper procedures, securing employee buy-in, and being vigilant of potential hazards. Your facility may already be taking steps to avoid cross-contact, but there may also be gaps in your system and preventive controls.
Don't leave your allergen cross-contact prevention to chance. Assign an expert from a trusted partner like AIB International to bolster your efforts, minimize your risk of non-compliance, and protect public health.
