Addressing Allergens in Your Meat Products
Notice 45-05 instructs inspectors to verify that establishments have adequately addressed the use of ingredients that either trigger allergic reactions or cause other adverse reactions in consumers due to food intolerances and sensitivities. This includes both the dry ingredients that are added to products, as well as any other ingredients that could come in contact with products (such as cleaners and sanitizers).
This Notice became necessary nearly two years ago, due to the high percentage of recalls that were a result of improperly labeled products or products otherwise contaminated with either allergens or ingredients causing intolerances. There are eight types of foods that are known to cause allergic reactions in some consumers and these include: wheat, Crustacea (e.g., shrimp, crab, lobster), eggs, fish, peanuts, milk, tree nuts (e.g., almonds, pecans, walnuts), and soybeans. These are the ingredients that processors have been taught to list in their product descriptions of their HACCP plans, as well as their product labels. Of these foods, eggs, milk products and soy proteins are most likely to be added to meat products.
Whereas, a lot of the recent recalls have been due to processors mislabeling products (making products which contained ingredients, such as soy or milk, which were not on the label), there are other opportunities for cross contamination of products (not intended to contain allergenic ingredients) with allergenic ingredients that are being used elsewhere in the operation, that need to be considered.
For example, if you make two batches of sausage on the same day, one containing no allergens, and one containing milk proteins, you could avoid the cross contamination by making the batch that contained the milk protein last. What if you make one batch containing milk proteins and one containing soy proteins? Doing one of the batches before the other doesn’t prevent the last batch from being contaminated with an ingredient that is likely not on the last product’s label. Potential solutions would be to do a clean up between these two batches or to not schedule both on the same day.
There is also the issue of slicing products that contain a variety of these potentially hazardous ingredients. For example, how do you handle slicing one product that contains milk protein and another that contains soy proteins? This could particularly be a problem in retail, when a customer requests slices of two types of products, one of which might contain an allergen.
How about something as simple and routine as the addition of dusty dry ingredients to meat in a mixer or chopper? Do you have procedures in place to prevent the cross contamination of these potentially hazardous dry ingredients onto uncovered containers of meat that are in the same processing room? That “dust” may seem insignificant to you, however, to a person with an allergy to that ingredient, it could cause a serious health issue, possibly even death.
However, there are a number of other ingredients, used in making meat products (including cleaners, sanitizers, etc.), which could cause adverse reactions in consumers of your products. These include monosodium glutamate (MSG), sulfites, lactose, Yellow 5, iodine, etc. Have you considered your sanitizers? Some consumers are allergic to iodine and could react to iodine residue on equipment that is sanitized with iodine, but not properly rinsed before use.
So how do you address these issues? USDA FSIS and ODA expect that these issues will be controlled through an establishment’s food safety systems (i.e., HACCP plans, SSOPs, or other prerequisite programs).
By Lynn Knipe, Ohio State University
In the pre-HACCP steps, you would first address these hazardous ingredients in the Product Description and the Flow Chart. Any intentionally added allergens (or other ingredients that could cause adverse reactions) should be listed in the Product Description. If you are purchasing an ingredient that is used in this plan, which is labeled “may contain soy proteins,” or “may contain milk proteins,” this information needs to be transferred to the Product Description of your HACCP plan, as well as to your label.
The Flow Chart should expose points in which these hazards would enter the process. For example, once the potentially hazardous ingredient is added to a product (or otherwise enter into the process), the Flow Chart can be used to identify all of the following steps in which this ingredient could contaminate equipment or other contact surfaces in your plant.
The Flow Chart would be most important when you are doing a hazard analysis of each step in the process. For example, at a mixing step in which you are adding an allergenic ingredient, you would need to address how you are controlling a potential hazard. This could include a prerequisite program in which you show the order of processing of batches, or how you otherwise separate this product from the other unpackaged products. This would include every other step in the Flow Chart (after mixing), in which the product might touch equipment or other products (e.g., stuffing, slicing, packaging, etc.) This might also involve a prerequisite program in which you show evidence that procedures are in place to prevent the accidental addition of the allergenic ingredient to other products.
At steps, such as mixing, stuffing, peeling (of casings), slicing, etc., the potential risks of cross contamination of potentially hazardous cleaners or sanitizers should be addressed. Hopefully, your SSOP program and records (e.g., how chemicals are stored, mixed and properly rinsed from equipment) would support that your process would prevent this type of cross contamination.
For products that are deep fried in soy oil, you would need to address the potential pick up of soy proteins onto the product from the oil, at the frying step.
At the packaging and/or labeling step, you would need to address how you ensure that products (particularly those containing potential allergens) are properly labeled. With sufficient records, this could be done with a prerequisite program, or it might require a CCP for labeling.
Of course, a rework step should be included in all HACCP Flow Charts, and how you address the handling of rework from products, which contain allergens is very important.
There are many ingredients, which contain the critical proteins that cause the adverse reactions and there are many names to consider in ingredient listings. The following list is a partial list of potentially hazardous ingredients, under the general allergen heading, that you might use to watch for ingredients that might be hidden in products that you purchase from other companies:
Soy Protein: soy lecithin, soy sauce, soy isolate, soy concentrate, soybean oil, hydrolyzed soy protein, soy flour, soy fiber, soy grits, textured vegetable protein, hydrolyzed vegetable protein (HVP)
Milk Proteins: sodium or calcium caseinate, casein, non-fat dry milk, whey powder, lactose reduced whey, milk protein hydrolysates, whey concentrate or isolate, lactalbumin, milk serum protein concentrates
Wheat Proteins: vital wheat gluten, hydrolyzed wheat gluten, wheat flour, wheat starch, wheat albumin, globulin, gliadin, soluble wheat protein (SWP), seitan, textured wheat protein
Egg proteins: egg whites, (ov)albumen, lipoproteins (yolk), lecithin (yolk)