For the millions of Americans with food allergies, the Food Allergen and Consumer Protection Act is more than just a government regulation, it's a matter of life and death.
For food and beverage manufacturers, the act is a matter of tightening their labeling practices, reevaluating their recipe management and switching to more automated systems that keep operator error to a minimum. With the new regulations, brand protection and customer safety have become more important than ever.
The Food Allergen and Consumer Protection Act was signed into law by President George W. Bush in August 2004. Manufacturers must comply by January 1, 2006. The legislation requires that food manufacturers clearly state the presence of any of the eight major food allergens (those responsible for more than 90% of allergic reactions) on their product labels: Milk, eggs, fish, shellfish, tree nuts (almonds, walnuts, pecans, etc.), wheat, peanuts and soybeans.
In the past, technical language (eggs referred to as "albumin," for example) or mislabeled products made choosing food a difficult task for consumers with allergies. This regulation provides a guarantee that food and beverage labels accurately reflect the contents of the product.
Perhaps most importantly, the act requires labels to identify the presence of major food allergens used in spices, flavorings, additives and colorings, which had previously been exempt from allergen labeling. The use of general terms, such as "flavorings," are not sufficient.
As the government acts to prevent allergen-related problems, manufacturers are under greater pressure to avoid mistakes, rather than concentrating on fixing them once they occur.
"If you look at the legislation out there-the Bioterrorism Act, for example-it is oriented more towards containment," Scot McLeod, vice president of marketing at Ross Systems (Atlanta, GA), said. "The food allergen act, in contrast, is geared more towards prevention."
Unlike the Bioterrorism Act, the emphasis is not on preventing deliberate contamination. "It is safe to say that food processors don't knowingly introduce allergens without identifying them," McLeod said.
Allergens often are unknowingly introduced into the product, and therefore not reflected on the label. For example, a manufacturer may use a substitute flavoring unaware that it contains an allergen.
To help prevent such "accidents," there are systems on the market, such as iRenaissance from Ross, that help track the specific contents of spices and additives. Such systems can give immediate visibility to the components in the event of an ingredient substitution.
For global companies, keeping up with worldwide regulations often presents a major challenge for manufacturers. Helpful software is available, such as Optiva from Formation Systems Inc. (Southborough, MA), that can quickly determine whether certain ingredients meet with the latest guidelines and regulations in different countries, and alert manufacturers when violations occur. This can be particularly useful during the development phase of new formulas.
In general, everyone along the food processing line should be aware of all ingredients involved. For example, a pizza manufacturer who uses dough from an outside source needs to verify all ingredients with the dough supplier. While responsibility may not rest solely on the pizza manufacturer, recalls due to allergens can harm the reputation of the brand appearing on the finished product.
Programs are available that can organize product information obtained from a variety of vendors working together in the creation of a finished product. Formation Systems provides one such system that can accept ingredient information from a variety of sources and formats -- spreadsheets, html documents, etc. -- and present it in a uniform fashion.
Barber Foods Inc. (Portland, ME), a gourmet frozen chicken manufacturer, faced some significant hurdles when it began declaring allergens on its labels. In the early stages, Barber's existing systems required numerous manual data-entry steps across several systems, which slowed the overall process and increased the likelihood of error. In essence, the more manual the system, the more hands involved inputting data and the more ingredients involved, the greater the chance that mistakes could occur. With that in mind, Barber contacted Formation Systems.
"It was so easy to miss something along the way," according to Herb Rau, director of quality at Barber. "With the implementation of this system, we attempted to simplify the process as much as possible."
With their breadings, for example, Barber is able to fully comply with the Food Allergen and Consumer Protection Act by employing its automated system to identify the numerous ingredients and subcomponents utilized to insure optimum flavor, texture and color.
While numerous errors can be attributed to recipe management and ingredient substitutions, mislabeling of products often is an issue as well. For example, in September, Nabisco Foods recalled its "Carry Me Packs" when the bags inside the Oreo boxes were found to contain Ritz Bits Cheese Sandwiches. Ritz Bits contain milk, while Oreos do not, and thus the Oreo labels did not indicate the presence of the milk allergen.
In the case of Nabisco the packaging error occurred at a supplier, pointing out the complexity of compliance when numerous functions are outsourced.
Utilizing a centralized management system for packaging information is one solution offered to help prevent such incidents. Centralized databases, such as one provided by 3M (St. Paul, MN), can reduce the opportunity for error, while also reducing production costs and the time it takes to get product to market.
"When we think about labeling, I think it's fair to say that there are specific business rules that need to be adhered to-look at it as fields of data that need to be managed," Mike Haldane, business process consultant at 3M, said. "In essence, we take artwork files, (place them in templates) and import them into the system, breaking the artwork down into pieces that can be managed-stored in a database with business rules that need to be enforced."
Consolidating information in an automated system is key to compliance.
As allergens become more of an issue, many companies are finding that they do not have the controls in place to meet the demands of proactive retailers and assure brand protection. It is important to be aware that numerous companies specialize in working side by side with manufacturing facilities to ensure both compliance and safety.