FDA issued a Warning Letter to Frito Lay for two allergen related issues that resulted in recalls. One occurred when at the Bakersfield, CA facility when incorrect seasoning containing undeclared milk was applied to Lay’s Barbecue Flavored Potato Chips and the other was a mislabeling issue at the Vancouver, WA facility when bags of Ruffles Cheddar & Sour Cream Potato Chip potato chips were labeled “Ruffles Original Potato Chips”. Basically, the two facilities had procedures but did not follow them.
Mislabeling at WA facility
According tot the report , the facility did not adequately implement food allergen controls at the packaging step allowing incorrect labeling where Ruffles Cheddar & Sour Cream Potato Chips were bagged as Ruffles Original bags, thus an undeclared major food allergen, milk.
In this case, the facility did not implement their roll change procedure - they were manufacturing Ruffles Cheddar & Sour Cream Potato Chips and intended to change the bagmaker to 1.5oz size Ruffles Cheddar & Sour Cream; however, the bagmaker operator incorrectly used the Ruffles Original film.
The allergen control procedure, “Film Splice Tracking,” is in place to indicate that at roll change the person will log the time, the identifying labeling film code, and attach the labeling film splice to the “Film Splice Verification” form, and then a second person will verify the labeling film code.
- These splice operations were not documented on the form.
- Also, the form indicates that the product should be identified, but on June 24, 2020, the product was not identified on this form.
- Further, the firm discontinued attaching the labeling film splice to the form in June of 2020.
Additionally, there was a procedure to verify the correct product is in the correct package and bag coding/case coding information is accurate. "The procedure also requires that the “Product” and “Flavor” be documented and that “Product Tasted / Correct Product in Bag?” is assessed and given a “GO or NO-GO.” On June 24, 2020, during the production of the recalled bags labeled “Ruffles Original Potato Chips” but containing Ruffles Cheddar & Sour Cream Potato Chips, “Product Tasted / Correct Product in Bag?” was given a “GO” even though the product documented on the form was Ruffles Cheddar & Sour Cream, and the label was “Ruffles Original.” Further wo employees signed the form, indicating that they verified the activities performed, and the discrepancy was not noted."
Allergen Cross Contact at the Bakersfield CA facility
The firm did not adequately implement the "Seasoning Allergens SSOP” and PSM (Product Safety Management) Procedure, which are allergen preventive control procedures to significantly minimize or prevent allergen cross-contact. "These procedures indicate that [the firm] will verify that all visible evidence of prior seasoning is removed [after] cleaning. On September 23, 2020, (b)(4) cleaning of packaging line (b)(4) in preparation for production of Lay’s Limón Flavored Potato Chips, orange residue, which was the same color as the seasoning used in milk-containing Ruffles Queso made immediately (b)(4) cleaning, was observed by our investigator. In particular, three orange residues approximately one millimeter in size were observed on the (b)(4) feeder (food contact surface), and two orange residues approximately one millimeter in size were observed on the interior surface of an unsealed finished product label for Lay’s Limón Flavored Potato Chips on the bagmaker of packaging Line (b)(4). These residues were observed after you conducted a (b)(4) clean-out and documented on your “(b)(4)” form that “the line has no visible evidence of previous products/seasoning run.” Further, a post-sanitation verification audit was conducted by your PSM auditor, and this area was determined to be ready for production and packaging of Lay’s Limón Flavored Potato Chips. Lay’s Limón Flavored Potato Chips do not contain milk."
FDA Warning Letter
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/frito-lay-inc-611243-11242020
WARNING LETTER
Frito-Lay, Inc.
MARCS-CMS 611243 — November 24, 2020
