Allergen Labeling Challenges

This example certainly illustrates governmental concerns about the need to prevent cross-contamination of food allergens during the manufacturing of multiple food products in the same time period, through one or more common processing steps in the plant. It also highlights the opportunities for enterprise business systems to help food processors better manage their people, processes and products, as a critical part of supporting compliance across all departments regarding these pending regulations.

Another way enterprise business systems can help food processors comply with upcoming regulations in the Food Allergen Act is by providing an automated way to imbed both product standards and critical manufacturing processing control points in support of strict adherence to policies and operational business rules to help prevent allergen cross-contamination of food products.

This includes the ability to record and display both target and actual quality properties of ingredients, intermediate bulk production, and finished products for every inventory and production inventory quantity and lot. Food processors will soon require the identification of allergen properties for all foods at every step of processing, as well as product lots going into inventory. This means enterprise business systems will need to allow food processors to clearly define ingredients with allergen properties and to imbed business rules as part of standard product formulations that describe how to manage work in process inventory and finished food products, because ingredient lists reflect known food allergens directly from formulated recipes. Product formulas and process routings will also need to identify potential cross-contamination points between products that share common processing equipment, including providing operator instructions based on best practices, regarding the movement and operational processing steps necessary to support disclosure of allergens and prevent cross-product contamination. A clear example of the value of preventing cross-contamination by defining clear operational instructions during processing is to establish strict operating guidelines around the handling of rework material (i.e., broken peanut butter cookies) during production.

Another opportunity for enterprise business systems to help manage disclosure and prevention of cross-product contamination of food allergens, is to help food processors define, record, and manage critical control points of key processing steps and management points, at the necessary level of detail, for processing allergen based foods. It will also be important to extend this level of control to the execution and recording of quality testing and related results, for both products and manufacturing processes. This includes enforcing business rules regarding material movement, handling, quality testing and operational processing of allergen based foods, in support of disclosure of allergens, and thus preventing the inadvertent cross-contamination of actual manufactured inventory lots.

But for food manufacturers to be successful today, it’s just as important that both employees and enterprise business systems understand when it may not be necessary to stop and perform expanded cleaning procedures of equipment used to manufacture multiple types of food products in a day, between production runs. Using the same example of the cookie manufacturer who might choose to first make sugar cookies, and then move on to make peanut butter cookies, the need for the same level of clean-up and change over between production runs may be reduced or eliminated, along with any risk of cross-contamination of peanuts into sugar cookies. This simple example illustrates how important enterprise business systems will be in honoring food allergen mandates, while still providing intelligent sequencing of food products sharing common processing lines, thereby protecting both the end consumer and the food processor’s capital equipment investment. Allowing manufacturers to imbed such business requirements into their processing preferences helps ensure compliance with regulatory mandates, while also organizing daily production runs to fully leverage available equipment capacity, and not merely based on a “first come, first serve” basis.