The U.S. Department of Agriculture’s Food Safety and Inspection Service
(FSIS) has issued guidance for identifying, controlling and labeling allergens
and other ingredients of public health concern through hazard analysis and
critical control point (HACCP) plans, standard operating procedures (SOPs)
or other prerequisite programs. Geared toward meat and poultry products,
the guidance seeks to ensure “that product labels declare all ingredients, as
required in the regulations, and that the product does not contain undeclared
allergens or other undeclared ingredients.”

In particular, the agency points to “a sustained increase in the number of
recalls of FSIS-regulated products that contained undeclared allergens,”
noting that such recalls are “preventable, as many have been due to ingredient
changes, product changes, products in the wrong package, or products
with misprinted labels.” In addition to establishing best practices for SOPs and
HACCP plans, the recommendations clarify how to properly process, handle,
store, and label a product with an allergenic ingredient or ingredient of public
health concern. The agency has requested comments by June 20, 2014. See
Federal Register, April 21, 2014.


Issue 521

About The Author


For decades, manufacturers, distributors and retailers at every link in the food chain have come to Shook, Hardy & Bacon to partner with a legal team that understands the issues they face in today's evolving food production industry. Shook attorneys work with some of the world's largest food, beverage and agribusiness companies to establish preventative measures, conduct internal audits, develop public relations strategies, and advance tort reform initiatives.

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