Undeclared Allergen Incident & Investigation Protocol Guidelines & checklists for allergen investigations at retail/foodservice, manufacturing and food import businesses

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  Sample of implicated batch ingredients
  

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  Sample of product (same batch if available)
  

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  Sample of end product – different batch (Validate relevant process(es))
  

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  Environmental swabs targeting relevant equipment, utensils and surfaces
  

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  Photograph storage, processing and packaging areas
  

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  Photograph food samples and swab sites, relevant processing areas, ingredient and product packaging/labelling
  



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  Photograph/copy product specifications, supplier information, label drafts & approvals, food processing/verification records
  



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  Does the food business import food/s containing allergens as prescribed by Standard 1.2.3 of the FSC:
  

 Peanuts & peanut products

 Soybeans & soybean products

 Milk & milk products

 Sesame seeds & sesame seed products

 Crustaceans & their products

 Cereals containing gluten & their products

 Sulphites (≥10mg/kg)

 Fish & fish products

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  Does the food business declare mandatory allergen information for the above allergens as required by Standard 1.2.3 of the FSC for the following foods:
  

food or to the purchaser verbally or in writing upon request of the customer



declared in documentation accompanying the catering food



declarations



connection with the food (e.g. displayed on outside of vending machine)



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  Does the food business import food product(s) which “claim” to be allergen free?
  

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  Has the food business received a complaint/s regarding a product suspected of containing undeclared allergen(s)?
  

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  Does the food business have a documented procedure for allergen identification for all imported food product(s)?
  

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  Are all employees trained in food allergen identification procedures?
  
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  Is there a training register available to verify training?
  



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  Can employees identify allergens of concern?
  

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  Does the food business import food(s) from a commercial supplier with a certified food safety program?
  
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  Does the supplier provide validation that the food(s) supplied are free of specific allergens?
  

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  Does the food business have valid documentation to enable trace back to the food supplier? E.g. Shipment records/invoices
  

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  Does the food business have a procedure/policy for assessing the allergen status of food/s received from suppliers?
  

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  Is there a procedure in place to review and approve all proposed product labels of all imported food(s) to ensure they are accurate and comply with the Food Standards Code? E.g. full ingredients list, batch coding (traceability), product specification
  
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  Does the procedure address the allergen status of the ingredients list and any required allergen declarations?
  
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  Has the food business demonstrated compliance with this procedure?
  




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  Is there a procedure/policy for ensuring any change in supplier is accompanied by an allergen status review of the product?
  

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  Do suppliers notify the food business of any changes in the allergen status and/or product formulation of food(s) they supply?
  
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  Has the business requested this notification from their suppliers?
  

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  Has the business validated the manufacturing process and end food product(s) to determine the allergen status of all imported food?
  
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  Is evidence available? E.g. end product testing results, food safety program records, supplier certifications, assess supplier’s allergen control plan, cleaning program & range of allergenic foods produced at their site.
  



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  Does the food business only accept foods that are adequately protected from contamination?
  

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  Does the food business only accept food(s) with adequate labelling and/or provided with appropriate documentation to determine the allergen status of the food?
  



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  Does the food business have a procedure to review all product specifications/documentation of imported food(s) for their allergen status upon receipt of a shipment?
  
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  Has the food business demonstrated compliance with this procedure?
  




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  Does the food business have a procedure in place to review all food product labels upon receipt to ensure they accurately reflect the product specification(s) and comply with the requirements of the Food Standards Code?
  
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  Has the food business demonstrated compliance with this procedure?
  

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  Is there a procedure in place to destroy or re-label food products which have been labelled incorrectly?
  





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  Does the food business have a system in place to clearly identify foods containing allergens at receipt? E.g.Tags/colour coding of cases/pallets
  



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  Does the food business apply any labels to imported food products?
  
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  Do product labels comply with the Food Standard Code requirements to ensure information is correct & product traceability is achievable? E.g. batch coding, accurate ingredients list, allergen declarations
  

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  Is there a procedure in place to ensure and verify correct product labels are used when labelling food products?
  
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  Are employees adequately trained in complying with this procedure?
  
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  Has the food business demonstrated compliance with this procedure?
  



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  Are labels applied to product(s) so they do not cover/obstruct other labelling information required by the Food Standards Code?
  

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  Is there a procedure in place to verify correct labels have been placed on products prior to distribution?
  
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  Has the food business demonstrated compliance with this procedure?
  

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  Is there a procedure for destroying old labels when product formulations have been changed?
  
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  Has the food business demonstrated compliance with this procedure?
  

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  Are food products distributed to manufacturing / retail / food service facilities?
  

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  Are all foods for distribution adequately contained or packaged to protect against contamination?
  



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  Does the food business only distribute foods that have adequate labelling as required by the FSC and/or provided with appropriate documentation to determine the allergen status of the food?
  

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  Does the food business have a documented food recall plan?
  

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  Can the food business demonstrate compliance with their recall plan when recalling unsafe food?
  



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  Sample of product (same batch if available)
  

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  Sample of product – (different batch)
  

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  Photograph of product packaging and labelling
  

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  Photograph/copy product specifications, supplier information, label drafts & approvals, shipment/import documentation, invoices of sale