This page provides a text alternative
for Volume 5, Number 7, available in full-color
Preventing the Production of Foods With Undeclared Food Allergens
By Kazuhiro Okumura, LTJG, USPHS
Imagine eating something and having a reaction that made it so difficult to breathe that you lose consciousness, go into shock,
or even die. This is the risk that people with food allergies live with everyday. For some people, simply being in the same room
with a particular food is enough to induce an allergic reaction.
People with food allergies must rely on being able to read the declared ingredients on labels to keep themselves safe.
This has become a great concern to FSIS because the Agency issued a large number of recalls in 2011 due to allergens. In 2011,
there were 48 recalls issued for undeclared ingredients. Undeclared allergens, potential public health hazards, accounted for 40 of
those recalls. In 2010, 18 recalls were issued due to undeclared allergens; and, in 2009, 14 were issued. Many of these recalls
could be traced back to when the product formulation was changed, or there was a change in a supplier's ingredient formulation
that was not reflected on the labeling of the finished meat or poultry.
The U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) has identified root causes when
recalls due to undeclared ingredients occur:
- The chemical (allergen) food safety hazard in a plant's hazard analysis has not been addressed;
- The establishment has failed to support the decision in the hazard analysis;
- The hazard analysis has not been reassessed; and
- Controls identified to mitigate the hazard have not been implemented.
Based on the highest number of cases in the population, there are eight foods that have been labeled as the "Big Eight Allergens."
- crustacean shellfish (e.g., shrimp, crab, lobster);
- tree nuts (e.g., almonds, pecans, walnuts); and
What are the steps you, as an establishment, can take to avoid recalls and potential harm to the public? Mark Wheeler of FSIS'
Labeling and Program Delivery Division says, "Check with all of your suppliers to make sure that their formulation is labeled
correctly, and make sure to declare all purchased ingredients correctly on the product label."
In addition, you want to make sure that the appropriate label is applied to each product and that your product is manufactured in
accordance with the product formula in the labeling record. A review of any prerequisite programs and targeted Sanitation Standard
Operating Procedures (SSOPs) is also a good idea to prevent any cross-contamination that may occur when producing multiple products.
Let's review what your responsibilities are by breaking down the process into three steps:
- Identify: All ingredients going into your product must be identified before the assembly process.
Inspect incoming non-meat ingredients by matching the label sketch and approval with the formulation to ensure label accuracy.
If there is a discrepancy, the ingredients must be held from use until they are correctly identified and properly labeled.
- Prevent: Your equipment must be designated or tagged if used for only allergenic ingredients, and sanitation and processing
procedures must be in place to prevent cross-contamination. One simple step you can take to prevent cross-contamination is to
handle and process non-allergenic ingredients before handling and processing allergenic ingredients. Critical control points
must be included within your Hazard Analysis and Critical Control Point (HACCP) plan, SSOPs, allergen control plan, or other
prerequisite program that sufficiently and effectively prevents the potential for undeclared allergens.
- Declare: Packaging and storing of allergenic and non-allergenic final meat products must also be separated and labeled
immediately according to their correct contents. Labeling procedures must be in place to ensure that the final product accurately
reflects the packaged product, and that product cannot be confirmed into commerce until the packaged product's label is approved.
If you have further questions on what you should do to prevent your product from being recalled due to allergens,
contact FSIS' Policy Development Division through askFSIS at http://askfsis.custhelp.com
or call (800) 233-3935. If your questions relate to FSIS' labeling requirements for ingredients, you may contact the Labeling and
Program Delivery Division through askFSIS using the Web link above or by calling (301) 504-0878.
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Do You Use a Systematic Approach to Humane Handling
By Jane Johnson, DVM
The U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) wants to remind all small and very small
slaughter plant owners and operators that the agency recommends that you use a systematic approach to humane handling. A systematic
approach focuses on treating livestock in a way that minimizes excitement, discomfort, and accidental
injury the entire time livestock is held in connection with slaughter.
To develop and maintain a systematic approach to meet the humane handling requirements, FSIS has stated that slaughter plants should:
- Conduct an initial assessment of where and under what circumstances livestock may experience excitement, discomfort, or accidental
injury while being handled in connection with slaughter and, except for establishments conducting ritual slaughter, where and under
what circumstances stunning problems may occur.
- Design facilities and implement practices that will minimize excitement, discomfort, and accidental injury to livestock.
- Evaluate handling methods periodically to ensure that they minimize excitement, discomfort, and accidental injury, and except
for establishments conducting ritual slaughter, evaluate stunning methods periodically to ensure that all livestock is rendered
insensible to pain by a single blow.
- Improve handling practices and modify facilities when necessary to minimize excitement, discomfort, and accidental injury to
In the first step of a systematic approach, you should conduct an assessment of where handling and stunning problems occur. You should consider such factors as whether:
- the movement of livestock is done with a minimum of excitement and discomfort to the animal and at a suitable pace;
- the particular livestock's genetics, instincts, and behavior are taken into account in the handling of livestock in the establishment;
- electric prods and other implements are used as little as possible to move animals within the establishment;
- animals have access to water;
- there is sufficient room in the holding pens for animals that are held overnight;
- training is provided for establishment personnel in the appropriate and proper use of restraints and prods; and
- potential weather and climatic conditions of the locale, especially for disabled livestock in the establishment, will lead to the inhumane treatment of animals.
In addition, you should also assess the stunning method used for your effectiveness in rendering animals immediately unconscious
and to ensure that animals are being properly stunned before being slaughtered. You should also assess the training for your employees
in the appropriate use of stunning and slaughtering equipment.
In the second step of a systematic approach, you should determine if you're in compliance with regulatory requirements by analyzing
- the pens, driveways, and ramps are designed and maintained to prevent injury or pain to the animals;
- the pens are free of loose boards or openings, so that the head, feet, or legs of an animal will not be injured;
- the floors of pens, ramps, and driveways are constructed so that an animal is not likely to fall (e.g., using cleated or waffled floors or sand on the floors); and
- driveways are designed so that sharp turns or sudden reversals of direction are minimized, so that they are not likely to cause injury to animals.
FSIS has more guidance on developing a systematic approach, as well as information on other aspects of humane handling, posted
on the agency's Web site at www.fsis.usda.gov/Regulations_&_Policies/
Here, you'll find the humane handling statutes and regulations, FSIS directives and notices, enforcement reports, training materials
(including the Humane Handling of Livestock and Poultry booklet, from which this article was taken), as well additional humane handling
For questions or assistance in obtaining more information on humane handling, you may wish to contact the Small Plant Help
Desk at (877) 374-7435. You may also send an email to
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Nutrition Information Charts Available as Resources
By Jane Johnson, DVM
On March 1, 2012, FSIS began requiring nutritional labeling of the major cuts of single-ingredient,
raw meat and poultry products, as well as on all ground or chopped meat and poultry products, with or
without added seasonings, unless an exemption applies.
In order to assist retail stores that sell meat and poultry products to post point-of-purchase nutrition
information, FSIS has created downloadable charts for printing. These charts show nutrition information for the
major cuts of meat and poultry. Retail stores are welcome to download, print, display, and/or distribute them to
consumers in close proximity to the relevant foods in the stores.
The charts may be accessed on FSIS' Web site at the following locations:
Chicken and Turkey
Pork and Lamb
Beef and Veal
If you are without Internet access, call the Small Plant Help Desk at 1-877-FSISHelp (1-877-374-7435) for
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Small Plant NEWS
Editor: Keith Payne
Managing Editor: Jane Johnson, DVM
Production: Joan Lindenberger, Sally Fernandez
Design: Gordon Wilson, Duane Robinson
Contact: Small Plant News, USDA/FSIS, Patriots Plaza III, Rm. 9-267A, Mailstop 3778
1400 Independence Ave., SW, Washington, DC 20250