Jennifer L. Johnson, Ph.D. Director of Food Safety & Quality Salm Partners LLC

From Keep good records and review them prior to shipping product

“The company changed ingredient suppliers, and the label was not changed to reflect the new ingredients” “The problem was discovered by FSIS during a routine label review, when it was determined that the label read lecithin, not “soy lecithin” as it should”

“Company changed ingredient suppliers and began using Worcestershire sauce, which contains anchovy puree, in its ingredient blend. The company’s label lists Worcestershire Sauce as an ingredient, but failed to list anchovy puree” “The inspector noticed the use of sour cream in making dough for the products, but no indication of milk as an ingredient on the label”

Never change ingredient suppliers unless you have verified that the “new” ingredient matches the “old” ingredient Request ingredient label & specification in advance of potential change Check these documents against label approval & finished product label Audit labels on first incoming load of “new” ingredient prior to releasing for use in production Be specific when labeling lecithin, starch, etc. Anchovy-containing Worcestershire Sauce should be avoided whenever possible

Not unreasonable to expect, for example, that An egg roll wrapper contains egg Teriyaki sauce contains wheat & soy

“The problem was discovered by the company during a label review, and occurred because of a printing error made by its label maker” “The problem… occurred because the spice blend used in the products contained cultured whey as an ingredient, which the company inadvertently left off the product label”

Know how your labels & labeled film are printed Gang printing? QA checks – type & extent of checks Always review label proofs for accuracy Audit incoming labeled packaging by comparing its ingredient statement to Finished product specifications Label approvals Labels on incoming ingredients

“The problem occurred when a company employee used labels from items produced earlier on the same day in similar packaging” “The product label indicates that the can contains Chicken Noodle Soup; however, it may contain Cream of Chicken Soup” “Southwest Style Chicken product packages may instead contain Chicken Pasta Pomodoro, which contains an undeclared allergen, egg”

Line extensions are a special concern Consider use of 2-D bar codes on label/labeled film coupled with in-line bar- code readers programmed with specific product bar codes

Recalls of meat/poultry-containing meal/snack kits due to incorrect pre-packaged sauce, dressing, or dessert component

Increased awareness benefits everyone and makes it more likely that errors will be caught before product leaves the establishment’s control Recall of duck products with sauce identified by a Distribution Center Recall of chicken breast patties with undeclared Isolated Soy Product identified by company accountants while performing routine weekly checks on production yields

Know your ingredients Pay special attention to formula expectations Ingredient statements on finished products must always be accurate Always put the right label on the product Assembling kits requires inclusion of the correct, properly-labeled components Review records prior to shipping product Train all employees on allergen control

Allergen Guidance FSIS Allergen Guidance Materials FSIS Notice (9/28/11) pdf pdf FSIS Notice (7/7/11) pdf pdf FSIS Directive Rev. 6 Attachment 2 (10/26/10) / pdf / pdf

FSIS Allergen Guidance Materials Voluntary Labeling Policy (3/15/07) ling_Allergens/index.asp ling_Allergens/index.asp Federal Register Notice ( 5/8/06) 016N.pdf 016N.pdf Q&A related to Ingredients of Public Health Concern (11/8/05) _for_Notice_45-05/index.asp _for_Notice_45-05/index.asp