Prevening Allergen Related Recalls Due to Mislabeling

The leading cause of recalls is allergens.  Case in point, 3 allergen-related recalls over the last two days due to mislabeling.  In two cases, the wrong preprinted label was placed on the food item, in the other, the wrong sauce mix packet added to the food package.

Prevention – making labeling a CCP – a critical control point to prevent a chemical hazard – allergens.  There are many companies that use multiple labels with varying allergens on each.  Having the additional attention that goes along with designating a process step as a CCP will require more thorough monitoring, verifying, and reporting.  For example, the label operator must sign-off on each pack or case of labels by reviewing the days production sheet as well as the formulation sheet in order to check for compliance with the label.  In addition, there would be verification of labels and formulation by QC and production supervisors, as well as daily sign-off by the HACCP coordinator.  All would be need to be trained in label review with an eye towards allergen identification.   I would argue that this step must be a CCP because based on industry history, hazards are not being prevented.  From a cost savings standpoint, although this added step will require operator time, it is cheaper than conducting a recall.