May 2016

Significantly, HARPC has changed allergen control through the Good Manufacturing Practices (GMP) revisions. In fact, over 25 allergen related GMP mentions can be found in HARPC. Recommendations have been replaced with required GMPs under the HARPC rule. Allergen cross-contact must be mentioned in the GMP’s. Allergen controls must also address handling, storage and use.

FSMA is changing how companies manage undeclared allergen risk during the production of finished products. For example, raw agricultural commodities are exempt from FALCPA. That does not mean there is not still a risk that a commodity ingredient contains an undeclared and unexpected allergen such as a peanut protein. Food fraud can also be an allergen source. An example of food fraud is an undocumented substitution of a cheaper peanut protein for an almond protein.

The Food Safety Modernization Act (FSMA) has posed significant changes in the food industry, with specific changes to allergen controls and good manufacturing practices (GMPs). Having GMPs for allergen control is no longer just a company best practice but a requirement of companies under FSMA.