Why Are Allergen Recalls Still Happening?

Undeclared allergens “still” make up the largest percentage of recalls overall. While recalls from pathogens like e-coli, listeria, and salmonella make headlines, recalls for undeclared allergens generally fly under the media wire. However, their impact to the public can be as injurious as pathogens to the consuming public.

Jen Bickerton, who reported on her case in Food Safety Magazine, called for food companies to consider the risk before rushing products to market. She suffered allergen food poisoning from a daily Harvest Meal Kit. “I suffered digestive symptoms lasting for days, horrible heartburn, abdominal pain, extreme fatigue, weakness, muscle and body aches, fever, dark urine, and intense itching.

I was so sick that I lost 10 pounds in a week. It has taken me months to recover from this ordeal, and still, I occasionally have abdominal pain/spasms in my liver region that make me concerned about long-lasting damage.

As quoted in Food Safety Magazine: “Food allergies involve an immune system response. When a person with a food allergy consumes the allergenic food, their immune system mistakenly identifies specific proteins in the food as harmful invaders, triggering an immune response. Anaphylaxis is an immune response that can be fatal if not treated right away.

Studies have shown that the eliciting dose of peanut protein to cause a systemic allergic reaction in the vulnerable population is estimated to be greater than or equal to 5 milligrams.”

The danger to the consumer for undeclared allergens is significant. In 2021, 6.2% of American adults have a food allergy and 8% of children have a food allergy. Alarmingly, 40% of children with food allergies in the USA have been treated in emergency rooms. Not to say that all these instances were because of food labeling (or a labeling error), but the threat of allergens is very real to the affected consumer.

I said “still” at the onset of this paper because as a percentage of all recalls, the number of allergen recalls is close to being the same in 2023 as they were in 2004 when the Food Allergen Labeling and Protection Act was passed.

Undeclared allergens accounted for,

• 47% of all recalls in 2022, and
• 63% of all recalls in 2023.

The FDA and USDA analysis of undeclared allergen recalls that the majority are due to loss of control during packaging and labeling:

• 70% of allergen recalls were due to loss of control during the packaging and labeling processes.

• About 15% of the mislabeling problems were from inadequate label approval.

• The remaining were from allergen cross contamination during production or from an ingredient supplier failing to disclose an allergen.

• Mislabeling occurred in large, midsized, and small food manufacturing facilities and in large and midsized retail grocery stores.

• 92% of recalls originated from food processors and 8% were from grocery stores.

We can and should do better. In the article for Food Safety Magazine, Yale Lary offers 7 steps meant to avoid undeclared allergens in the labeling process. It’s time that companies take note and enhance their controls of food labeling and decrease the number of recalls related to undeclared allergens. The seven steps Yale offers in his article are sound recommendations to take a hard internal look at your own systems, controls, and responsibilities.

The data and analysis in this blog are based on Quality and Food Safety Magazine articles:

A. OCTOBER 12, 2023 Recalls Due to Undeclared Allergens Can Be Prevented: It Starts with Proper Controls During Packaging and Labeling.

By Yale Lary

B. OCTOBER 04, 2023 An Industry Insider’s Perspective on Becoming a Food Poisoning Victim. By Jen Bickerton