Canadian Food Inspection Agency
Bureau of Food Safety and Consumer Protection Food Safety Investigations Program
National Sector
Assessment 2000 - Import Sector Labelling and
Allergen Controls in the Import Sector
FINAL REPORT and RECOMMENDATIONS
WHY AND HOW THE ASSESSMENT WAS DONE:
The presence of undeclared allergens in imported foods may result in minor
to life-threatening allergic reactions in persons with food allergies. The most
commonly known allergen is peanuts. However there are several other allergens
and their derivatives which are known to cause most adverse food reactions,
they include the following:
- Peanuts
- Tree Nuts (almond, Brazil nut, cashew, hazelnut (filbert), macadamia
nut, pecans, pine nut, pistachio, walnuts)
- Sesame Seeds
- Milk
- Eggs
|
- Fish, Crustaceans and Shellfish (e.g. crab,
lobster, shrimp, crayfish, clams, mussels, oysters, scallops)
- Soy
- Wheat
- Sulphites
|
The presence of undeclared allergens in food products can lead to costly
recalls. During the past year almost 54% of all allergy related recalls
coordinated by the Canadian Food Inspection Agency (CFIA) resulted from
imported foods.
To promote allergen awareness and evaluate the controls needed to reduce the
risk of allergic reactions from imported foods, the CFIA conducted a nationwide
assessment of labelling and allergen controls in the import sector. The
assessment started with the distribution of an information package which was
sent to approximately 3,700 importers. Then from June 1999 to February 2000
on-site assessments were conducted of 116 randomly selected importers. During
the assessment product labels were examined to verify label accuracy against
the available product information. An importer survey was also completed to
assist in understanding the importing environment and general labelling
practices.
Only the importers who are primarily regulated under the Food and Drugs
Act and Regulations were included in the on-site assessments. Four criteria
for labelling and allergen controls were used in on-site assessments (the four
criteria are not new requirements, and are already being used to reduce the
likelihood of allergic reactions to imported foods).
They are:
- Product Information |
- Label Accuracy |
- Product Handling |
- Allergen Awareness |
For each importer, applicable criteria were assessed and rated as Complete,
Partial or Absent and a report was provided to each importer.
WHAT WAS FOUND DURING THE ASSESSMENT - HIGHLIGHTS
The assessment found that there was a lack of available product information
at importers, such as identification of specific ingredients, components and
additives including allergens as well as processing and handling information.
When information was available it was often up to date and complete. For the
majority of importers, procedures for ensuring label accuracy were considered
inadequate. Importers predominantly handled pre-packaged and pre-labeled
products, though some importers also re-packaged or re-labeled imported
products. Eighty-six percent of importers were aware of the allergy concerns.
This awareness, however mainly focused on peanuts. Only a few had a complete
formal policy or allergy-related employee training.
In the Survey, importers reported on their current allergy related
activities. Twenty-three percent had previously received an allergy related
complaint or had dealt with the presence of undeclared allergens in their
products. Forty-six percent had been asked by their customers to provide
allergy related information. Forty-one percent had asked their suppliers to
provide allergy related information, and 29% supplied products with
precautionary statements, i.e., may contain nuts. Additionally, 18% had taken
some action to improve controls after receiving the information package from
CFIA.
The assessment ratings indicate the need for importers to improve labelling
and allergen controls in order to ensure that accurate product information is
obtained from suppliers and conveyed to customers. Some importers realizing the
need to improve their controls took the following types of corrective
actions:
- Requested product information from suppliers
|
- Started employee training |
- Reviewed labels |
WHAT IMPORTERS CAN DO TO IMPROVE CONTROLS -
RECOMMENDATIONS
Based on the CFIA findings the following recommendations are made:
1. PRODUCT INFORMATION : An importer should ensure that complete
and current written information/ specifications are available for each
product. |
This may be achieved by:
- maintaining written information sheets for all products;
- regularly updating and controlling (eg. initial, date, verify, etc.)
information sheets;
- identifying (eg. supplier, brand, etc.) and listing amounts of specific
ingredients, including food additives;
- identifying all nine food allergens when present;
- including processing or product handling information (eg. frying oil, egg
washes, pan coatings, etc.) to determine the need for precautionary statements
(eg. may contain...) on product labels.
- Ask for product information preferably before purchase or at least at
the time of purchase, using a supplier checklist or an equivalent document.
[see attached]
- Keep and update a product information binder and ensure accessibility to
all staff. Plasticizing sheets may prevent unauthorized changes and ensure
durability.
- Include special product handling instructions on information sheet (eg.
"pack as the last batch for the shift").
- Include brand names, names of suppliers and issue date on product
information sheets.
2 . LABEL ACCURACY : An importer should ensure
that the composition of the product is accurately represented on the
label. |
This may be achieved by:
- verifying that the ingredient list (including precautionary statements) of
each product is accurate by checking it against available product
information;
- ensuring that any formula substitutions are reflected on the label;
- ensuring that precautionary statements on product labels are current,
accurately reflect product information provided by suppliers, follow the list
of ingredients and are not used in lieu of good manufacturing practices;
- disseminating clear, timely and accurate information about ingredients to
appropriate personnel;
- matching all new labels or precautionary labels developed by the importer
against product formulations and associated manufacturing or handling
information.
- Make a person responsible for maintaining and updating all
labels.
- Use written procedures to verify the accuracy of new and existing labels
(eg. ingredient checklist).
- Identify the source of ingredients (eg. hydrolyzed soy protein,
wheat starch, modified wheat starch, soy lecithin,
etc.)
- Declare peanuts, milk, soy, eggs, sesame seeds, sulphites, wheat,
treenuts, fish, crustaceans and shellfish and their derivatives even when
exempted under the Food and Drug Regulations.
- Check that all labels, especially those generated by in-house label
printers or when purchased from a new printing company, accurately and legibly
contain required label information.
- Check all labels to ensure all labelling requirements are met, including
mandatory information and accurate nutritional information.
3. PRODUCT HANDLING PRACTICES: An importer should control the
handling of products and packaging materials, in order to prevent possible
contamination and mis-labelling. |
This may be achieved by controlling:
- shipping, receiving and storage;
- use of equipment involved with opened products;
- repackaging/labelling;
- on-site retailing operations.
- If re-packing, ensure that every opened product is transported, stored
and packaged in a manner that avoids contamination with undeclared allergens,
i.e. dedicated packing lines for high risk allergens or a full clean-up between
product change-overs.
- Promptly close or cover all opened containers and clean all
spills.
- If labelling match the product against the label. Also, proper storage
and removal of unnecessary products and labels from the immediate area helps
avoids mis-labelling.
- When using brokers, third party warehousing or direct shipping ensure by
means of spot checks, written contracts, letters of guarantee or certificates
that the product is always being handled properly to prevent possible
contamination with undeclared allergens.
4. ALLERGEN AWARENESS POLICY: The importer should implement a corporate
allergy policy, including employee training on food allergens. |
This may be achieved by:
- documenting and implementing an allergy policy;
- training employees in appropriate labelling and allergen controls.
- Company policy on allergens should address all allergens most frequently
associated with allergic reactions (see list on page 1).
- Include all employees in allergy training.
- Make a person or a team responsible to plan, implement and monitor
allergen and labelling controls.
- Inform your suppliers and customers about the policy.
- Check to ensure that policy is being followed.
WHY IMPORTERS SHOULD IMPROVE CONTROLS
Importers are the primary link between imported foods and consumers and play
a very important role in ensuring the safety of imported foods for consumers.
The CFIA expects that importers will apply the required labelling and allergen
controls to:
- Meet their legal responsibility to ensure the safety of their
products;
- Provide accurate information to their customers;
- Improve the safety of imported products for people with food
allergies;
- Avoid allergy related complaints, costly recalls and product
withdrawals.
In the future, the CFIA may use the results of this assessment as a baseline
to measure changes in the labelling and allergen controls within the import
sector.
WHERE TO GET MORE INFORMATION
To obtain further information concerning the assessment and for assistance
regarding the labelling of foods, food safety or related information, please
visit the CFIA Web site or contact CFIA office nearest you via Government of
Canada information line at 1-800-O-Canada.
For further information on food safety and food labelling, including
proposed enhanced labelling initiatives to make label declaration of priority
allergens mandatory, please visit the Health Canada Web site at www.hc-sc.gc.ca.
|