Allergen Control: Beyond the Label

Why This Matters

Undeclared allergens are the leading cause of food recalls in the U.S., accounting for nearly half of all recall events in 2024. Of those label-related recalls, a staggering 83.85% stemmed from undeclared allergens. The average cost of a single recall? $10 million, not including lawsuits, reputational damage, or lost sales.

What Auditors See That You Might Miss

Auditors don’t just look at your label—they trace allergen risk through your entire system. Here’s where undeclared allergens often hide:

• Shared tools: Scoops, slicers, or utensils used across allergen and non-allergen products.
• Rework: Reintroducing product into the system without allergen traceability.
• Label printing: Manual label entry or outdated templates that miss allergens.
• Ingredient swaps: Last-minute substitutions not reflected in the label.
• Sanitation gaps: Incomplete cleaning between allergen runs, especially in dry environments.

How to Build Auditor-Visible Allergen Control

• Labeling: Automate label control and link it to approved formulations. Use mock audits to verify label accuracy.
• Separation: Create visual zoning, color-coded tools, and time-based scheduling to isolate allergens.
• Spill Clean-Up: Develop a technician-proof SOP with allergen-specific response steps and disposal protocols.
• Cleaning Validation: Use swabbing, ATP testing, or visual checks to confirm allergen removal—especially in dry clean areas.
• Create an allergen flow map: Show where allergens enter, move, and exit your system.
• Train for competence, not just compliance: Use verbal checks, not just sign-offs.
• Audit your sanitation program: Validate allergen removal with swabbing or visual checks.

Final Thought

Allergen control isn’t just about avoiding recalls—it’s about protecting lives. Auditors see beyond the label. So should you.

When “Corrective Action” Is Just Damage Control And What Corrective Action Is Not

Most facilities treat corrective action like a fire extinguisher—grab it when things go wrong, spray the problem and file the report. But clause-backed corrective action isn’t about optics or containment. It’s about systemic recalibration.

• Damage control is reactive.
• Corrective action is architectural.

Start with the Right Problem

A corrective action plan begins with a precise problem statement—not a solution, or a justification.

• Define the issue without solving it.
• Let clause cues guide your lens:
1. “Systemic” → not isolated
2. “Repeat finding” → ineffective past action
3. “Gap in control” → architectural flaw

If the finding reads like déjà vu, your system isn’t learning—it’s looping.

🔌 Corrective Action Is a Switch

Think of corrective action like a switch:

• Insert it → the problem disappears
• Remove it → the problem returns

If the issue persists with post-correction, you didn’t find the root—you found a symptom.

• Root cause analysis isn’t about blame.
• It’s about solving correcting the system that created the problem

🛠️ Correction vs. Corrective Action

Correction: An immediate fix to contain or resolve the issue (e.g. Re-cleaning a contaminated surface)

Corrective Action: Systemic change to prevent recurrence, based on root cause analysis (e.g. Revising sanitation SOP and retraining)

🎯 Match the Action to the Cause

If your root cause is “lack of training,” your corrective action isn’t “update the SOP.” The action must directly neutralize the root cause.

✅ Verification Isn’t a Checkbox

Verification must evaluate effectiveness, not just confirm completion.

Ask:

• Did the problem reoccur?
• Did the system behave differently post-action?
• Can we prove the fix worked under stress?

🌐 Preventive Action—The Look Across

Preventive action isn’t a bonus—it’s a systems mindset.

Use the root cause to scan adjacent systems:

• If one SOP was flawed, are others built on the same logic?
• If one operator misunderstood, is the training model flawed?

Corrective action closes the loop. Preventive action expands the lens.

🧭 Closing Thought

Corrective action isn’t a form. It’s a philosophy. When done right, it’s the difference between a facility that survives audits—and one that evolves through them.

Legacy isn’t built on fixes. It’s built

HACCP Without Blind Spots

By: M.R. Trace

Hazard Analysis and Critical Control Points (HACCP) is the backbone of food safety systems. It’s clause-backed, globally recognized, and mandatory in regulated environments. But here’s the uncomfortable truth:

Many HACCP plans look complete—until you audit them.

WHAT I SEE AS AN AUDITOR

I’ve reviewed hundreds of HACCP plans. Some are robust. Most are performative. Here are recurring gaps that compromise safety, traceability, and credibility:

• No mention of rework – Product re-entering the process isn’t addressed. Risk is recycled, not mitigated.
• Waste streams ignored – Disposal logic is missing. What leaves the system isn’t tracked.
• Customer returns excluded – Returned product is outside the hazard lens. That’s a blind spot.
• Flow chart not verified by HACCP Coordinator – No signature, no ownership. Just a diagram.
• Flow chart doesn’t match hazard analysis – Steps are skipped, merged, or mislabeled. The map doesn’t match the terrain.
• High-risk steps identified but not mitigated – Hazards are acknowledged, then left hanging. No CCP. No control.
• No clause-backed justification for exclusions – “Not applicable” is used like white-out, not like logic.

If a step is excluded, it must be evaluated and justified—per clause, not convenience.

METAL DETECTOR ≠ HACCP PLAN

One of the most common missteps I see:
Facilities treat the metal detector as their only Critical Control Point
It’s installed, calibrated, and documented—so they assume the job is done.

But here’s the clause-backed reality:

• Metal detection addresses one hazard type metal fragments.
• It does not mitigate biological, chemical, or other physical hazards (e.g., brittle plastic, glass, bone).
• It’s a last-line defense, not a comprehensive control strategy.

If your HACCP plan has one CCP — and its metal detection—you better have clause-backed justification for every other hazard being controlled upstream.

Otherwise, you’re not managing risk. You’re outsourcing it to a machine.

WHAT A CLAUSE-BACKED HACCP PLAN LOOKS LIKE

• Every process step is mapped, verified, and owned
• Rework, waste, and returns are addressed with hazard logic
• High-risk steps trigger mitigation — not just acknowledgment
• Flow chart and hazard analysis are synchronized and clause-referenced
• HACCP Coordinator signs off — not just in theory, but in practice
• Not applicable is justified with clause-backed rationale, not convenience
• CCPs are validated — not assumed

FINAL THOUGHT

HACCP plans don’t fail because the hazards are invisible. They fail because the system pretends not to see them. If your flow chart is decorative, your hazard analysis is incomplete, your CCPs are unvalidated, and your exclusions are unexamined— you don’t have a HACCP plan. You have a liability.

What a Food Safety Team Should Actually Be Doing

By: M.R. Trace

In most facilities, the food safety team gets mentioned in audits, training slides, and org charts—but what does it actually *do*? More importantly, what *should* it be doing?

Let’s strip away the fluff and look at the real work of a food safety team, not the ceremonial stuff. The operational stuff. The kind that keeps systems sharp, risks visible, and decisions grounded.

First, Define the Team

A food safety team isn’t just QA and the plant manager. It’s **cross-functional by design**. That means:

• Production brings process realities
• Sanitation brings frontline insight
• Maintenance brings equipment context
• Purchasing brings supplier and spec awareness
• R&D or Product Development brings formulation foresight
• Quality/Regulatory brings system oversight

When these voices are in the room, the team becomes a **decision-making engine**, not just a compliance checkpoint.

What Should Be on the Agenda?

Here’s what a food safety team should be reviewing regularly—not just when an auditor’s coming:

1. Site Inspection Nonconformances

• Review internal audits, GMP walks, and sanitation inspections
• Trend findings over timeespecially repeat offenders
• Focus on identifying and correcting root causes, not just surface fixes

2. Ingredient, Process, Customer Changes or Product Changes

• Any new ingredient, equipment, or formulation should trigger a review
• Focus especially on new allergens — even trace introductions
• Ask: Has this change been risk-assessed and communicated clearly?

3. HACCP Plan Review

• Revisit hazard analysis when processes shift or new risks emerge
• Don’t just “update the document” — challenge the assumptions
• Ask: Is our plan still relevant to what’s actually happening on the floor?

4. PRP and CCP/Preventive Control Effectiveness

• Review monitoring records and corrective actions
• Look for patterns: missed checks, repeated deviations, vague responses
• Ask: Are our controls working, or are we just checking boxes?

Final Thought

The food safety team isn’t a formality. It’s a forum. A place where operations, quality, and strategy intersect. When it’s functioning well, it doesn’t just protect the brand—it drives continual improvement.