Since mid-2016, a new question has been included in the post recall report required for all food recalls, asking food businesses what caused the issue to occur. FSANZ has reviewed allergen-related recalls and identified four categories of problems with undeclared allergens:
1. Lack of skills and knowledge of labelling requirements, for example:
- pasta was declared as an ingredient, but wheat was not
- manufacturer reformulated ingredients – however did not reflect new ingredients on labelling
- the ingredients were not fully-translated into English from the original language.
2. Supplier verification issues, for example:
3. Packaging errors, for example:
- product packed in the wrong packaging
- dairy free claim on front of packet when it was meant to be a gluten free claim - ingredient list was correct
4. Accidental cross contamination either of a raw ingredient, or during final production process.
These problems were identified via consumer complaints, distributor or retailer complaints, company and government testing and/or in-house testing. The corrective actions taken by food businesses included education and training for staff, amended processes and procedures and product labels. Further details are provided below.
Problem detection has always been collected as part of the post recall report. It is broken down into five categories with an 'other' category provided to allow explanation for detection that does not fit within the four categories.
There were 33 undeclared allergen recalls in 2016 (46%), 34 (49%) in 2017 and 46 (46%) in 2018. In the last three years, customer complaints were the most common method of detecting the need to recall food followed by routine testing by the company and then routine government testing (table 1, figure 1). As seen in figure 2, detection by customer complaints and routine testing by the company has increased since 2016 and detection by government testing has decreased.
Table 1. Problem detection for undeclared allergen recalls 2016 - 2018
|Distributor or retailer complaint||3||3||1||7|
|Routine government testing||8||6||5||19|
|Routine testing by the company||6||8||14||28|
Figure 1. Problem detection for undeclared allergen recalls for 2016 - 2018
Figure 2. Problem detection for undeclared allergen recalls by year (2016 – 2018)
How the recall occurred
The root cause question was added into the post recall report in mid-2016. As it was added later in the year, a full year of data is unavailable. The raw numbers can be seen in table 2 and the percentage of these numbers can be seen in table 3. By using percentages, this allows the data to be compared against 2017 and 2018.
Packaging errors are the leading cause of undeclared allergen recalls (Figure 3). The exception to this was in 2016 when supplier verification issues were the leading cause. Unknown causes can be due to the food business not being able to determine the root cause or FSANZ did not receive any post recall information from the business following their recall. Although FSANZ sends reminders to food businesses, to provide post recall information, some still need follow up. Figure 4 shows that there has been an increase in unknown root causes.
Table 2. Root cause for undeclared allergens food recalls by year
|lack of skills and knowledge||0||0||2|
|supplier verification issues||6||3||6|
Table 3. Root cause for undeclared allergens food recalls as a percentage by year
|lack of skills and knowledge||0%||0%||4%|
|supplier verification issues||50%||9%||13%|
Figure 3. Root cause for all undeclared allergen food recalls (mid-2016 – 2018)
Figure 4. Root cause percentage for undeclared allergen food recalls by year
Thirteen food businesses listed no corrective actions in their recall reporting. However, for the majority of businesses, they included a selection of corrective actions. These are listed below:
- Training of staff
- Improved communication procedures
- Altered product ingredients
- Altered product label
- Changed suppliers
- New/changed equipment
- Amended processing/handling procedures
- Identified new critical control points
- Improved manufacturing process (GMP's)
- Improved hygiene practices (GHP's)