0:04
Hello, everyone.
0:06
It's a pleasure to welcome you to our Common Causes of Allergy and Recalls webinar in collaboration with the FDF and Camden VRI.
0:15
I'm Kelvin Sampson and I'm Marsha's Food and Beverage Industry Sector Leader, and I will be hosting this webinar today.
0:24
Just a bit of housekeeping. The webinar is scheduled to last 45 minutes.
0:29
Audience members can submit questions for the panel by typing them into the window at the bottom of your computer screen.
0:35
We'll also have a couple of polling questions during the slides.
0:41
So we have a great panel with us today. So let me introduce them to you. You can see them on the screen now.
0:48
We have Oli Amy, a regulatory manager at FDF. Hello, Oli Amy.
0:54
We have Wendy, a safety quality and Manager of Camden BRI, welcome Wendy.
0:59
And my colleagues at Marsh, I have Anna Maria, Product Risk Management Consultant, and also Tim, who's head of our product recall team.
1:08
So welcome to you all.
1:11
Next slide, please.
1:13
Just to, so now you can move that on actually.
1:18
Thank you very much.
1:21
So just a bit of context really.
1:23
In the first quarter of 2025, European product recalls reached nearly 4000, surpassing 3500 for the fifth consecutive quarter and marking the highest quarterly total in 11 years.
1:38
In the last few weeks, Iceland has had to recall their sub-rolls because a batch contained barley and gluten wasn't mentioned on the labelling.
1:46
We also have ZZ having to recall pizza products because they contain milk that wasn't declared on the label.
1:55
Just recently, well even today, I've seen that Lidl had to recall some protein bars because the label failed to disclose in English that the bars contained milk and soya.
2:05
And an interesting one with Haribo as well, although it's not a UK prescribed allergen or I don't think it is, they've recalled packets of sweets alleged to have contained cannabis after several members of the same family have fell ill to quite an interesting development.
2:27
And I'm not an allergen, I have to confess, I've got my colleagues on here with our allergen experts. I don't think that cannabis is one of 14 prescribed UK allergens.
2:37
There'd be better to tell you more than me.
2:41
So really a single labeling error, cross-contamination incident or undeclared allergen can trigger product recall with serious consequences.
2:51
They could be financial, operational disruption, but also reputational damage and even legal exposure.
2:59
So today, with our expert panel, we'll be unpacking the risks surrounding allergen recalls and we'll provide insight into all of the topics that you can see in front of you today.
3:12
And with that, Oli, Amy, if I pass over to you, if that's okay?
3:19
It's perfect.
3:20
Thank you, everyone.
3:22
And thanks, Kelvin, for that really good introduction and recall stats, especially around allergens.
3:29
So, morning, everyone, and thank you for the opportunity today.
3:33
I've only got a few minutes.
3:35
So if you move the slide to the next one please, just to spend with you, I've got about six slides just to go over briefly food safety incidents, paying attention to allergen recalls and guidance to food businesses.
3:50
So when we talk about food safety incidents these are events where there's a potential or actual risk to public health due to the consumption of the food and it can involve allergens, chemical, microbiological or physical contamination.
4:05
I mean, in the context of this webinar today, we're focusing on allergens as we've kind of seen that it's just really just rife in the news with a lot of recalls.
4:16
And these four things that you can see on your screen right now, they are hazards that need to be considered and managed accordingly.
4:23
So risk assessments, looking at the likelihood, looking at the severity, and sort of incorporating, you know, the finders into your risk food safety management plan.
4:33
Now with regards to allergen food safety incidents, it means the product has got a non-declared allergen. It's, you know, either cross-contaminated or is incorrectly labelled.
4:43
So, and this situation is not something that every single person is affected, but there are people, there are allergic consumers, and they can have as low as mild reactions to serious life-threatening reactions to anaphylaxis, which you don't want to happen.
5:01
You know, if you look at a scenario where if an undeclared allergen is on a pre-packed product that perhaps has a free-from claim on it for that allergen and the consumer that is at risk consumes it, I mean, the consequence is just really quite damning.
5:15
So we need to pay attention to allergen recalls, not because of their frequency, but because of the potential consequence for consumers and businesses, and we can talk about the things that can be incorporated and kind of help us as we navigate this space. So next slide, please.
5:37
So I just want to spend a few seconds sort of saying we should, you know, like, why should we pay attention to allergen recalls?
5:44
Well, we should because they directly impact consumer safety, as I have said in my previously, the consumers relying on the label of accuracy.
5:53
so even a small oversight can have serious consequences for them.
5:58
And as Kelvin's mentioned, recalls can damage brand reputation.
6:04
You have your consumer confidence that could be ruined as a result.
6:08
You know, you kind of look at things like cost implication, that would probably vary from where each business sits in the supply chain.
6:17
So you could be more of a B2B or a B2C supplier and the cost will vary differently based on where you are.
6:25
Or even if you're looking at the nature of the recall.
6:28
So when you look at the cost of a misprinted label that has no contamination issues to perhaps an incident that is multi-layered, multi-business, it becomes even more.
6:39
So there is quite a lot of impact there.
6:41
But what I really want to pull out from this is not only should we be paying attention to allergen recalls, we should really be using it a form of horizon scanning. So don't wait until your business is impacted before you do something.
6:55
Take it as a kind of nearness.
6:57
If you're hearing the news that there are some issues with a particular ingredient or product, even if your business is not buying from that region or that supplier, just look at it through a horizon scanning, do a risk assessment.
7:09
Again, check that your supply chain is not impacted or going to be impacted.
7:14
Or if you think you've identified that a risk, then start looking at mitigations around it.
7:20
Because really, what we don't want is to be in a situation where undeclared allergens become something that you're dealing with.
7:28
And I will explain a bit more about what I'm trying to talk about here around the fact that undeclared allergens being the leading causes of food recalls in my next slide.
7:40
So if I just have a next slide as well please.
7:46
So I've got some stats here and you know I think in addition to what Kelvin's mentioned earlier these are more or less the numbers that show that in allergen in terms of the food recalls if you kind of consider all the four hazards I mentioned earlier allergen incidents tops it all and it's often due to mislabelling or you know things to do with labelling And I've got this stat saying NIS priority allergens.
8:17
And I know I had my previous slide earlier that there are 14 UK EU regulated allergens.
8:22
So when I say priority allergens, I am talking about these regulated allergens.
8:27
And they are the ones that are quite in terms of prevalence in terms of maybe the risk or maybe the reaction levels are the ones that have been identified as, you know, causing the most reactions in certain allergic consumers.
8:40
And we just have a recurrence around the same things bordering around this recall.
8:48
So what are the causes? What's contributing to?
8:51
What are the things that as food businesses, we need to begin to look at? So if I start off by saying, labelling errors is a big thing.
8:59
Simply having incorrect or missing allergen information, where it does not conform to the food information regulation, perhaps the allergens not being boldened, or it's in a different language from what's on the packaging is enough to, you know, if an allergic consumer picks that up, that is enough to cause, you know, like problems because we are confusing them and they cannot see, you know, like identify easily that there is a risk, you know, for them. You've got packaging mistakes. That is quite a high one.
9:28
When you look at the FSA stats, which is available on the FSA website, actually, you can see quite a lot of recalls and you see things like wrong products in packaging or package ingredients not on the allergen ingredient not declared.
9:43
So I'll say mismatched product packaging errors is just quite a very big one. There are things around incorrect free from claims.
9:51
Again, I mentioned earlier, you know, like if someone's relying on a particular food because it says it's free from dairy, but then somehow within the supply chain, there is sort of somehow been introduced without knowing that is a risk to the person.
10:06
And the stats you're seeing on the screen right now, they're not just a UK representative stats.
10:11
I mean, if you look globally, the same, you know, like stats from America, Canada, Australia, it's more, it's just the same thing.
10:20
There's just like labelling errors, incorrect allergen information, packaging mistakes, incorrect free from claims.
10:27
The other big one is unintended allergen presence, you know, not declaring it.
10:31
So this is where precautionary allergen labelling or may contain comes in.
10:38
So, this could be as a result of things like maybe cross-contact from like poor cleaning practices, inadequate supply or risk assessments, and just a lot of things that could sort of bring in that allergen into your supply chain or into your products without you intending for it to be there.
10:55
Now, I'll just add here very briefly that there is work ongoing to standardise the may contain or power at the codex level, and the UK is very involved in that.
11:07
But it still doesn't say that we shouldn't be trying to do our risk assessment, you know, which we're not going to have to wait until they standardise the approach or the process or how it's done before we make sure that we're incorporating that and thinking about that when we are doing our allergen risk assessments.
11:24
And a very good example around unintended allergen presence will be the recent peanut and mustard allergen incident.
11:30
And that was a big one that took place between, I'll say September to like late December last year.
11:38
A lot of us would have heard about this either from a consumer level or even from food business.
11:44
It was quite a big thing.
11:46
And without going into details of the actual incident and just sort of giving a brief overview.
11:52
So what it was was we had peanut contamination in mustard flour or ingredient from origin and then across the supply chain.
12:01
So we had a vertical and horizontal situation going on in terms of the unintended allergen presence.
12:09
So what actions were taken at the time? So it led to a UK wide product recall.
12:14
Like I said, it was just all over the news and everywhere.
12:17
There was thorough investigations to try and get to the root cause or the factors surrounding why it happened.
12:24
And, you know, like I said, there's a lot of information available about it on the FSA website, but I just wanted to give my view on this and use it to bring in what things should be looked at when we are, I'll say, conducting our risk assessments and trying to prevent allergen recalls. So could it have been prevented?
12:43
Well, my view is perhaps yes, or I could say maybe it could have been prevented up to a scale where it's not as wide as it happened.
12:54
And if I look at the details behind the incident, for me, it raised a lot of questions around, you know, assessing the risk in the supply chain and in ingredients and sort of conducting that risk assessment, like how has it been done?
13:08
And risk assessments are not like serious mathematical computations or anything.
13:13
They could be as simple as really just thoroughly asking the right questions, investigating your supplier, making sure that you have understood what it is that is needed and your supplier understands it as well.
13:27
There was a communication issues, what information was available, so what do we do with information that we received from our supplier and what was done to it?
13:35
Was it passed up, was it passed down, was it passed across the supply chain?
13:39
I think those questions were things that I would say, if we're really looking to them, I would want to use that.
13:45
If I was planning or looking at my allergen management for my organisation, I will use that to look at what systems I've got in place to make sure that it's quite robust.
13:55
Then there's the training and then there's the education.
13:58
That is one thing to train, but it's also one thing to ensure that that training is well understood and the allergen education, you know, the information is absolutely completely Traceability was another thing, you know, again, and I talked about communication because that's connected. How is that information moving up and down? What's been kept?
14:17
What's been stored and all that. And then finally, having an effective recall process.
14:24
So I said earlier, I said, you know, could you have been prevented?
14:27
Yes, or maybe not to the same scale.
14:30
Perhaps if there was an effective recall process in place from the food business is perhaps we may not have, it would have been contained as soon as it was discovered.
14:38
We shouldn't just have recalls in place for audit compliance.
14:42
They should be like active processes that we really look at.
14:47
So on this slide here, I'll say my advice or sort of looking at experience from working several years in manufacturing is to really just take learnings from incidents like this, even if you're not impacted, but use it to review your allergy management plan to keep it robust, reassess your allergy and risks within your supply chain, your factories, your processes, and really look at how you can make things different.
15:15
And those are those things that I would say are some of the contributory factors that will be surrounding an incident from taking place.
15:24
And the other part of it will be to not just wait for something to happen, but if there are near misses, if things have been observed as a near miss, then it makes sense to really investigate a near miss and make sure that it's sort of corrected and to put in a prevention in place, because a near miss today could become a big incident tomorrow.
15:47
And I will sort of now sort of give you a bit of, you know, like, what guidance is out there available for businesses? So if I have the next slide, please. Thank you.
15:59
So, speaking of having a robust allergen management in place, there are so many, such a lot of resources out there that are quite useful.
16:08
However, I'm going to just really focus on the FTF allergen report prevention guidance today.
16:15
And that is really just sort of telling you, you know, it's basically a piece of guidance or I'll call it toolkit that highlights factors that should considered when assessing allergen risk. And I mentioned four things earlier at the start.
16:31
You know, I talked about incorrectly or not declaring allergenic in regions.
16:36
I talked about mismatch of product packaging, incorrect free from claims, not declaring the unintentional allergen presence.
16:45
So, what is in that guidance, what it does is it takes a deeper look into those because they are the recurring reasons when you look at any stats globally, you will find those four things are clearly identified.
16:58
What it does, so the guidance is quite sort of very simply written, highlight the importance of having an Allergy and Risk Management System, investigating your incident or near misses and looking at, you know, the fact that I said about near misses not being ignored, because when it's ignored, you could end up having an incident later.
17:19
It then does a deep dive into where they could occur, problems that could cause them, and any key prevention considerations, which I will go into.
17:31
What is important to notice, the information in the guidance is not exhaustive. It recognises that everyone's got a unique business.
17:39
Each operation is unique, so Your risk assessment is quite subjective to your operations, but what is important is to actually have something and have it. It's free to download guidance on the FDF website.
17:54
It sort of gives you quite a lot of information on what to consider in terms of where you're looking at.
18:02
And the other part of it is it doesn't just focus on the one thing, for example, the way the problem may happen could be anywhere in your business.
18:10
So, for example, you can't just say you're looking at one end of a process without looking at the entire, I'll say, take a holistic view of your processes. Don't just look at the factory. Look outside of it.
18:24
Look at your supply chain.
18:25
Look at how it's sort of coming in and all the routes that it's to come in. Can I have the next slide please? Thank you.
18:36
So here I just want to spend the last few minutes just to talk about what not to do or what businesses don't want to fall into.
18:46
So if I can I look on the left side of my screen here, you know, you really want to look at some of the things on there and say, you know, for example, I've got their precautionary, contain labels protected against liability, but they don't diffuse inappropriately.
19:03
So it's quite important that if you're going to end up using a precautionary allergen labelling, or it may contain, it's been done or used when you've conducted your risk assessment properly.
19:14
And I mentioned at the start, even though, yes, there is work on standardisation going on, it doesn't mean that you still cannot assess the risks to the best of the information.
19:25
and that's why, or that's where making sure you've got the right information is necessary to help make that whole objective.
19:33
Say, okay, this is definitely, it may contain rather than, oh, I'm just using it to cover myself.
19:38
So we don't want to see businesses sort of falling into that bracket of just covering themselves.
19:44
And then the other thing is inadequate specification control system.
19:47
So sometimes, you know, you could receive your product specification when it's received? Is it just received and kept somewhere until the next review?
19:56
Is it received and sort of assessed?
19:58
Are you implementing a robust approval programme such that you are interrogating the specification and making sure it matches what you're getting from your supplier and just sort of checking that supply chain is what it is?
20:12
So, you know, again, you just don't want to collect information for the sake of audit purposes or sort of tick in the box, we want to really make sure that they are enough to sort of support whatever decisions are going to be taken from an allergy management point of view.
20:31
So, key preventions in the guidance, which you will find is sort of, you know, and this is something, you know, I would say just continue to sort of ensure your, you know, look at ingredient accuracy.
20:42
So, for example, if all wanting to kind of investigate a sort of a unintentional origin presence, then, you know, how do you ensure your ingredients accuracy? How do you do your own research?
20:56
So the advice is you to kind of really discuss with your supplier.
20:59
Advice is to check origin versus processing region or country of origin.
21:04
So I often see things like country of origin will say some things with of origin EU, but you know, you kind of have a country of origin as EU, it needs to be a country.
21:14
So if you have that kind of information on a specification, that raises questions that you need to look into.
21:21
In terms of like, if you're implementing a verification process for your labelling, it doesn't mean you only do it at the end where the labelling step is in your process.
21:31
You could start, you need to start from the beginning, you know, what, who's approving the who are they, what are the various sign-offs that takes place before them to make sure that information is not lost in translation, to make sure that, for example, that bold allergen ingredient is carried through to the end.
21:50
The other part of it is, it sort of talks about cross-contact prevention, how do you strengthen your cleaning protocol, making sure they are validating and verifying properly.
22:01
And then he also advises about partnering and working with accredited laboratories to discuss your allergen testing needs because then you get the expert advice needed around analyticals and make sure that it's also supporting what you're doing. So there's quite a lot of information in the guidance.
22:18
Like I said, it's quite freely available and it's sort of quite a useful piece of document for businesses to incorporate.
22:28
So before I kind of end my section, I just want to sense check where the audience is. And I just want to run a poll quickly.
22:42
So yeah, I'm just so what is the biggest allergen risk in your business? And there are five options for you to select.
22:50
You've got either labeling or packaging errors, cross contact during production, inaccurate supply information, staff training gaps or other.
23:01
So I'll just give a few seconds for you to vote. I think we are great. Right.
23:20
I can see here that we've got inaccurate supply information as the probably highest and then label and packaging errors slash cross contact during production is sort of, I'll say quite close to each other.
23:33
So no, you for that. So this is interesting.
23:36
So definitely inaccurate supply information, I would say, is one of the big things as well.
23:42
And how do you get over that is to try and develop a relationship with your supplier and let your supplier understand your product, what you're doing with it.
23:55
Possibly not, you know, like, I mean, I understand that sometimes you may want to protect like, say, brand and where it's going, but you need to let them know what your, what the allergen regulation is in the country where your product is going to, for example.
24:07
So, if you're making something that's going to say Japan, they've got different, they've got about 29 regulated allergens.
24:15
So, you need to make sure that whatever you're making and going into that country meets that requirement.
24:22
But it's just making sure that you are, I'll say, yeah, investigating your supplier, making sure that the supply chain that you know ask deeper questions about this where exactly is the ingredient coming from you know don't just accept its process somewhere try and find out where the origin is and how it gets to you and that should probably really help thank you for that and can I have the next slide please so it closing from me my final advice is sort of I'll I just want to encourage businesses to integrate active allergen management into their food safety plans. Let's not have tick box allergen management just to comply with audit.
25:07
Investigation is quite key and sort of horizon scanning is quite key.
25:11
Don't ignore an allergen recall that you hear about in the news because it's nothing to do with your business. You never know.
25:18
It may be something to do with your business in the future.
25:20
So you want to make sure you are using the information you're getting to just re-analyze what you've got in place already.
25:28
And I just want to stress the importance of being proactive in allergy management.
25:33
I'm moving away from reactive recall cycles because that would save a lot in the long run, brand reputation, consumer trust.
25:42
And finally, before I hand over to Wendy, I just want to say, let's continue to manage allergy risks better, develop proper mitigation steps, and prevent future incidents or manage them better and improve our processes.
25:55
And thank you for that.
25:56
And I will hand over to Wendy.
26:01
Thank you, Olé.
26:02
Yes, I'm Wendy Duncan, and I work at Camden BRI.
26:06
And at Camden BRI, we support the food industry in many different ways in relation to allergy management.
26:11
The kind of things that we do, we obviously support our members, but we support non-members as well.
26:16
And the kind of support that we can give is actually we do documentation review, we create gap analysis reports from that, We do proactive site visits to help support assessing the allergy management processes in place, but we also do reactive support as well So when an incident has occurred and how we can support that customer in order to help them rectify those issues by doing root cause analysis So they can start to work on their continuous improvement of their food allergy management processes So with all that in mind, I wanted to share on the next slide kind of what some of the good and or the bad practices look like, and with regards to allergy recall incidents. So you all have heard some of this already, that's because it's so important.
27:03
So Ole and I are definitely on the same page.
27:06
So in terms of recalls, I think it's really important to be prepared. Like Ole said, it's really about making sure you don't ignore those near misses.
27:14
But also I think it's really important that people actually have a process in place.
27:19
So in order to make sure that it works, it's actually very important to have a mock recall, to do that scenario testing.
27:25
You can do a mock recall internally, you can do a mock recall with one of your key customers, and you can work through that process to make sure it works for both of you.
27:35
So that is a really, really good way of testing your process and really making sure you've got that traceability and you really understand every step and the roles that people play as well.
27:45
And having that commitment of the process at the leadership level as well is really important.
27:50
When an incident happens, you want everybody to know exactly what their role is and to deal with that as a priority.
27:58
So you can make sure you can rectify it straight away. Another thing we see is a lack of formal allergy management plans.
28:06
So don't just rely on your hygiene processes and your sort of basic hazard to fill that you've got your allergens covered. That's not necessarily the case.
28:18
So you really need to have an allergy management system in place so you understand your controls and that's integrated into your quality systems.
28:26
But it's important that that is also a, it's dedicated focus on the allergy management.
28:34
Also, we see often inadequate food allergy mapping inadequacies.
28:41
So really understanding how that allergen, that raw material moves through your factory is important to consider where it's been before it hits your site.
28:52
However, once you manage it yourselves, how you intake that raw material, what's the flow of that material, who's coming in contact with it, you know, so it's really good to understand exactly kind of what lines it's going to, what areas, what equipment it's touching, so you have that full visibility.
29:13
And then you can kind of identify where the risks are and really try and identify maybe if things need to be managed slightly differently in order to limit that movement of that particular allergen and reduce that cross-contact.
29:27
Another thing that is very confusing that's already been touched on today is the whole precautionary allergen or alibi labelling, which either is not implemented accurately. Like Ola says, you need to do your risk assessment.
29:42
It's not a legal requirement, but you do need to do your legal risk assessment and comply with food safety regulations as well.
29:49
And you also need to make sure you have got the right supply allergen information in place.
29:55
So you've got to have processes in place that enable you manage this and again it's already been said it's about having proactive internal controls, it's having that allergy mapping, it's having that cleaning validation done with regards to allergens, it's having that verified as well and then also it's managing that product, assessing it as it goes through through to like you've got your pre-launch reviews but you'll have your post-launch reviews and you're also looking at making sure when you're producing you've got NPD, are you introducing new allergens to that line, that area, to your factory?
30:34
Is it an allergen people would expect to have in that product?
30:38
We shouldn't really be adding anything that's not kind of expected.
30:43
And also, when there are recipe changes, does that have an impact on the allergy labeling? And this is all very important.
30:50
And is that be changed due to your internal decisions, or is that because it's been brought about by a supplier, not being able to supply anymore or changing their raw material?
31:01
So it's having those controls internally to ensure that you can really manage all of that, your raw materials and any change of status.
31:13
So if we go on to the next slide and we look at two case studies, which I'm not going to go into the case studies in detail. However, it's just an example.
31:22
It's already been mentioned today.
31:24
One of the major issues with allergen recalls is label errors or wrong packaging with the wrong product.
31:37
So in this particular instance, so the first one was an egg was not labeled. So it was a very similar product. They'd use different packaging.
31:47
So there's of packaging controls.
31:49
The second one, with the case of the carrot cake and cookies, that contained milk.
31:54
So the milk was in there, it just was not, it was more specification management issue, so it wasn't picked up through the development process, and that allergen then got sort of transferred into the final product, but actually the raw material did have the milk in.
32:11
So it's kind of, if the specifications had been correct, then that would have come through to the final labelling stage.
32:19
So in terms of the types of lessons you can learn through these types of recall situations is it's that, as we've already touched on, it's not just about regulatory compliance.
32:30
There is an awful lot of best practice out there and guidance to help support to enable you to do the most accurate labelling but accurate management of your allergens on site.
32:42
It's really important that your products are clearly labelled, they're accurate, and you are using the correct packaging.
32:49
This is really important when we look at how we manage packaging, version controls, packaging switchovers on production lines, and so forth.
33:02
These things do go wrong too often.
33:07
Internal processes need to be validated, as I said, and they need to be verified. You need to try and prevent issues where possible.
33:14
That's why when Ola was saying risk assessments are so important, so you need to risk assess your processes and they will help to prevent any incidents happening, but also they will help you detect issues far more quickly if something does happen.
33:31
And then obviously they need to be reviewed.
33:34
It's about that continuous improvement that's always going on, which is why the assessment of near misses is so important and then so valuable to get those to build that into your processes.
33:48
Allergy and checks as part of the final product verification is very important, so not just relying on it at recipe level, what's going into the system actually does, what you put into the product actually match what is on the label.
34:01
Allergy matrices should also be updated when recipes change.
34:05
As I said, you need to have a good robust internal processes for managing specification changes, suppliers changes, your own recipe changes, recipe updates, you know if there's ingredient shortages and you're having to switch in new ingredients, how do you manage that that is an appropriate ingredient and things like that. So you need to have those processes in place dedicated to the allergy management.
34:29
You need to have internal sort of internal sort of really robust traceability and with this a testing programme which will support your verification processes within your allergy management programmes.
34:42
I think another thing that's really important is actually about comms.
34:46
When it comes to a recall you need to be, I always say, speed but not panic.
34:51
So you need to be very calm, you need to approach it with with speed and pace but sort of getting the transparency, the clarity, gathering the data and there's some clear ownership in the business and who is managing the issue and who is managing the communications of the issue and ensuring can get obviously that communication out as quickly as possible when that is needed.
35:14
There's also the implementation.
35:16
So the incident management process is such an important process to have and as I said already actually to have that process in place and test that process is so important.
35:26
So make sure you have an established process, review that process and test that process is so important and have that process agreed to and commitment from the very senior part of your business, leadership support, because if something does happen, then everybody knows that that can be their priority.
35:47
They can focus on that, deal with that, and then they can resolve the issue as quickly as possible.
35:54
So again, as we've already said, it's so important because it's all about protecting the consumer.
35:58
The consumer has the right to eating safe food wherever they are.
36:02
And also, it's very important for your brand and your company reputation. Now I'd like to hand over to Anne-Maria.
36:13
Thank you. So yeah, thank you. Thank you, Wendy. So hello all. I'm Anne-Maria.
36:19
I'm part of the MARS team.
36:21
And basically I'm here to give you some additional insights from the product risk consultancy perspective, but always in alignment to what my fellow panellists have already shared with you.
36:34
So now the focus on this slide is on actually the characteristic we see consistently in businesses that have strong allergen controls in place.
36:45
So basically those businesses that are finding themselves dealing less frequently with recalls.
36:53
First one is that allergen management system in those businesses is embedded in the quality culture.
37:01
So, allergen management is not basically just a checklist or maybe a compliance type of task.
37:09
It is treated with similar seriousness as overall food safety or hygiene, and the business actively views it as of priority at any particular point in time.
37:23
Second is that there is strong focus on dual verification and what this practically means, this means that labels, recipes and other specifications are kind of cross-checked by at least two people from, ideally from different teams.
37:44
For example, that could be technical or engineering team and production.
37:50
This approach kind of helps to avoid label mix-ups that can actually trigger major recalls as you might imagine.
38:02
Another recall threat I wish to highlight is ownership.
38:06
So businesses that are handling allergen controls successfully have set clear accountabilities around allergen risk.
38:18
So, allergen management is part of their KPIs for example, their internal trainings also, but there are in addition clear escalation paths with regards to the incidents linked to allergen management.
38:35
You would kind of be surprised if we let you know many businesses, how many clients of us we hear that they don't actually have named a person owning this area and this might be proven as of a detrimental mistake.
38:54
Again, also for good performing businesses, what we see is that they run regular internal traceability tests, which includes a allergen tracing.
39:06
So what they do is that they don't just wait for an incident to find out if their systems are actively working or effectively working, they do test those systems and thinks promptly what basically doesn't hold up.
39:22
In addition, and this comes definitely in alignment to what's mentioned by Olajemi and Wendy, those businesses are viewing a recall from the proactive lens and not the reactive lens so they prioritize incident preparedness that might include a running recall simulation with potentially allergen scenarios or tracing how quickly they can identify a single allergen containing baths.
39:52
So you can think of it as of let's say a forward-looking effort that those businesses are doing that differentiates that Potentially differentiates between a close call and a public crisis or a massive reputational crisis and finally a last point that is also linked to proactiveness with regards to incident preparedness is learning from past recalls and this is crucial because good performing businesses are actively and consistently reviewing past recalls accumulating the knowledge coming out of them and I'm not talking about only past recalls that those businesses per se have experienced, but also looking at the industry, looking at what their competitors are doing, what have they done wrong, or what have they done good, and basically adopt respective practices that they feel would work for them or will help them ameliorate the allergen controls that they do have in place.
40:55
So, now that we have kind of looked at a very high level, what strong allergen management looks like, maybe we can move it to a more practical approach.
41:05
And if okay, Luke, can we move to the next slide?
41:09
Because here we have some more, let's say straightforward tips that could be applicable to any business, like no matter the size, no matter the product that is produced.
41:21
So the idea is that you can take those away from today's session, backed up with additional tips that Olajemi has shared earlier.
41:29
And you can start apply from tomorrow, wherever it sticks with your organization.
41:35
So first is on auditing your labels.
41:40
And yeah, this might sound generic, but I don't just mean like glance at a few packs.
41:45
I mean, go do a thorough, let's say audit, like go line by line and even compare your product labels to your current recipes, added specification, supplier declarations because in reality it's alarming how often those small changes can can slip through and those small changes could come from new ingredients or reformulations to existing ingredients in the product or minor minor in your eyes supplier that never make it into the final pack, but might lead to an allergen contamination at the end of the day.
42:25
Second, but linked to what I just said on the audit, is maybe you can take a moment and recheck your supplier allergen declaration.
42:36
So this is especially important for ingredients like spice plants or coatings or sauces.
42:45
So in essence the kinds of things that contain hidden allergens or where recipes can vary or change slightly due to seasonality.
42:56
It would be a good tip to start asking your suppliers questions like, oh has anything changed since last time we got this ingredient for you and try document their responses, like have a robust tracker for that.
43:11
Next one, if you haven't already, like it would be good to start making sure that line leaders and bikers, all people down the supply chain are trained specifically on allotment critical steps, not just generic general food safety.
43:31
Those, let's say, more targeted trainings could include changeovers, could include line clearance and label checks. And why suggest that?
43:42
It's because in reality it is those people, like people onboarded on those roles, are the ones that are closest to the error point.
43:52
But if you flip the coin on the other side, those are the people who closest to the point of prevention. So it's good to spot more light towards this direction.
44:04
Another great exercise is basically to run frequently allergen recall simulations, if you don't do this again already.
44:15
So you can ask yourself questions such as, okay, let's say an allergen issue comes up tomorrow, how quickly could we as a business trace the affected product? Who should we call first?
44:29
Or do we know who goes out and reaches to our retailers, who notifies our end customers?
44:37
So questions like that could help you prompt the thinking, could help you understand that running simulations is crucial so that if an event occurs, everyone knows their role, everyone is confident with the process.
44:52
And when talking about simulation, I'm not having in mind something that is super complicated, even let's say tabletop exercise, 30 minutes, one hour can reveal way more valuable gaps that you can imagine.
45:10
And yeah, finally is that, make allergen risk, make effective allergen management conversations as part of your, let's say, daily agendas, like thinking, either by bringing it into your morning, afternoon, cut-ups meeting with the teams, or by putting together an allergen matrix for the business and taking it on a monthly basis.
45:38
What I suggest, or basically the idea here, is just don't let it be something you only think after an event occurs, after something goes wrong.
45:48
Because at the end of the day, the business that succeed in allergen controls are the ones who treat allergen management as of a constant priority and not as of one-off project, if that makes sense.
46:06
So, yeah, that was everything I wish to cover on this slide.
46:10
and having said all that, this basically lead us to the second poll of the day.
46:18
And look, thank you. And this is on product recall insurance, as you can see.
46:25
And this is the topic, actually, we'll start discussing in a moment.
46:29
So the question basically here is, does your business have a product recall insurance that covers allergen incidents?
46:37
So the answer is yes, but we've reviewed it recently. Yes, but not sure what's covered on the insurance.
46:46
No, but we are considering it or no, not in the radar and then not applicable in our business if or I'm sure if it is applicable for our business. So giving you a couple of extra seconds on that.
47:09
Okay, so I think prominent answer based on your vote is it's not applicable to our business and Yeah, that is followed. Yeah, we do have, but we're not sure what's covered.
47:24
Okay, those are interesting responses.
47:27
And yeah, I'll pass it now over to our recall, product recall expert, basically, who can give us more insights and tell us how the answer to the poll looks like to him.
47:40
Thanks, Anna. Appreciate that.
47:42
So look, yeah, we spent a lot of time looking at the policies procedures and things that you can do to implement or reduce the risk of allergens.
47:51
But being honest, when those issues do slip through the gap, through the net, you want to make sure that actually there's protection to the business.
47:59
And when we look at this, we're looking at an insurance solution, we're looking at a risk transfer solution.
48:06
So we talk about product recall far too loosely when it comes to insurance. And what we're actually focusing on is a contamination policy.
48:13
Obviously, in today's focus, that contaminant is going to be an allergen as opposed to one of the physical or chemical points that were raised earlier.
48:23
Looking at this slide, we've got a spread of different events that a contaminated product policy would respond to.
48:30
You've got accidental contamination, a product extortion, tampering event, a mandated recall from a regulator, an adverse publicity, and a product defect piece there.
48:40
In those blue boxes, we've got more of a focus around, well, what are some of the scenarios?
48:45
What are the things that would need to happen for an insurance policy to protect you against a contamination risk?
48:52
And again, honing in on the allergen side of things, which is gonna be the most applicable there.
48:57
It's the accidental contamination piece.
48:59
In essence, the accidental contamination trigger is there to help you when you've put a product into market or created a product, manufactured a product, which would result in bodily injury.
49:12
Now some of the scenarios that have come up in the conversation already this morning, that would include things like putting the wrong product in the wrong packaging.
49:19
It's a product that's got nuts in, it's gone into the packaging, it doesn't say it's got nuts in.
49:24
It could be an issue just purely with the packaging, the fact that you've missed an allergen off it, or you've used an allergen which is in the wrong language or a label in the wrong language which Kelvin alluded to earlier.
49:37
But what was interesting actually on that first poll and tying this piece into it is that what the policy will also respond to is actually if you've used an ingredient that's been mislabeled and supplied to you, so you might be completely unaware that the ingredient that you have used has been mislabeled and contains an allergen.
49:57
Even though it's not your fault, if you've manufactured the product and subsequently identified the allergen is in the product, and obviously the allergen would go on to bodily injury then this policy is going to be looking at providing you with the protection there.
50:15
So again it's important to think about when do these policies start, when does the insurance start, what are you going to get cover for and actually it's the point of the contamination.
50:25
If you've identified that there's an allergen in your production line in the product that shouldn't be there that's when the clock will start ticking.
50:34
So if we move on to the next slide we'll actually, okay, well, what gets covered under a policy?
50:39
We've identified actually there's an allergen in the product.
50:41
It shouldn't be in the product.
50:43
What are we gonna do about it?
50:44
Well, where are you in that production process?
50:47
If you've identified it in the production line, you're gonna have to stop that line.
50:52
You're gonna have to clean it down.
50:54
You might need to destroy the products that you've already manufactured.
50:58
If the product has left your care custody control, it's gone out to the retailer or a distribution center, you've got to actually get it back.
51:05
Is it a chilled product?
51:06
Have you got extra costs in terms of storing it in a chilled warehouse?
51:11
Have you got the capacity to bring the product back?
51:13
Do you need to go and engage with third party warehousing to get the product stored there?
51:18
All of those types of costs would get picked up under these policies.
51:23
But the key thing here to keep in mind is that we're not really just focusing on the recall costs here.
51:29
The biggest cost a few years ago when one of the insurers was calculating it was around the business interruption.
51:35
So if you lose a contract as a result of providing a product which is contaminated with an unknown allergen or mislabeled, then actually these policies can indemnify you.
51:46
They can give you that business continuity, the peace of mind of understanding that actually any downturn in sales can get claimed for under these policies.
51:57
And I think it's really key just to make sure that people understand that.
52:02
Because often, like I said, we talk about recall and it's not a recall policy, it's a contamination policy and we think it's gonna cover the recall costs and that's the main focus of it.
52:11
We know what the main cost is, is the business interruption piece.
52:14
So when we hit that pause button and we try and help clients understand what it is that the insurance can offer, there's a bit of a light bulb moment because a lot of people think that actually a recall won't happen to me.
52:26
We've got the best policies and procedures in place, But obviously from our perspective, you can't control everything that could go wrong and this is the sleep easy This is the product that's going to help give you that protection for when someone else causes you the issue that you couldn't really manage or test for because you can't test every single product that comes Through your doors and you never know and what will have been put into the products that you might be using into an ingredient that you Might be using If we just skip on to this next slide from my side of things, please.
53:01
From my perspective, how do we manage it?
53:04
What are we really thinking about?
53:06
Policies and procedures are great, but you can't ensure they're being adhered to 100% of the time.
53:12
That's a reality.
53:13
If it's temporary staff that you've got coming in because you've got a peak production that you need to hit to hit a Christmas market, an Easter market, or another seasonal market, Actually, your volumes are going up, and actually people might not be fully trained or adhering to those policies and procedures.
53:30
Like I said, you can't test for everything, so you don't know effectively what contaminant could be in your product.
53:39
We've been in the situations where we've had clients come to us and say, we've never had an issue before, the 100-year-old company, and then lo and behold, they have an issue, then they have to go out and seek investment elsewhere just to keep the business afloat. And if you are buying insurance, is it the right insurance?
53:57
If you're buying an extension, a recall extension, that's not going to cover you for half of what you could get covered for on a standalone basis.
54:07
Don't just rely on those recall extensions because like I've said, a contamination policy is going to start the clock ticking a lot earlier.
54:15
You don't have moral hazard of having to release the product, the product being out there.
54:19
It's at the point that you establish you've got a problem which would cause bodily injury.
54:25
The other side is think about where you sit in the supply chain. Again, this came up earlier.
54:29
What are you trying to protect if you do have an allergen issue?
54:32
Is it a case of you are an ingredient manufacturer and now subsequently your contaminated product has been used as an ingredient in someone else's?
54:41
That's huge third-party risk, or is it your brand?
54:43
Is it your product that you want to protect?
54:46
And actually, we should be focusing much more on that.
54:49
Understanding whether you're using co-manufacturers, because these policies will provide you for protection against them causing you an issue as well.
54:59
I think what we really want you to go away with from my perspective, from the insurance piece, is that there's huge misconceptions about recall policy, recall insurance.
55:10
And actually, if you take the time to understand what you can actually be covered for, you'll be amazed with actually the number of different scenarios that the policy can respond to, but equally the breadth of covered loss that you can get protection for.
55:26
And the key one there, like I said, really is that business interruption.
55:30
I'm conscious of time.
55:31
I hope I've whet the appetite with respect to what the risk transfer solution looks like, but we're always happy for further conversations.
55:38
But with that, I shall pass back over to Kelvin.
55:42
Yeah, thanks, Tim, very much.
55:44
Look, I really apologize for going over time, but some really fantastic content.
55:48
And it's been a pleasure to host you all today.
55:50
Thank you for joining us.
55:51
And I really thank our expert panel for their insights and expertise today.
56:00
We'll be sending out a copy of today's presentation to all those that registered and attended.
56:05
please do reach out to us if you have any questions.
56:09
Have a good rest of the day. Thank you very much.
