FS & RD Consulting
Food Safety And Research and Development Consulting




Food Safety – How the past can shape the future!


Looking back at 2018 we can see many significant recalls but they can typically placed into 2 main categories

  1. Undeclared allergens

  2. Bacterial – salmonella, e.coli and Listeria monocytogenes as the top 3

  3. Physical – glass, plastic, extraneous material entering the product.

Some examples from 2018 include: E.coli in Romaine lettuce, Salmonella in chicken products, LM in smoked salmon, and undeclared milk in Almond milk. We also saw a new and emerging threat of E.Coli 0129 in flour.

By investigating and understanding why these things occur, we can better understand what programs should be put in place to reduce and/or greatly eliminate these risks. These programs are:

  • Allergen management, Labelling

  • Preventive controls including Sanitation, Maintenance, etc.


An allergen is a substance that is foreign to the body and can cause an adverse reaction in certain people. For example, pollen, nuts or mould This adverse food reaction can either be a food intolerance or a food allergy. Allergic reactions to foods can be vary from mild gastrointestinal discomfort, to skin rashes and/or potentially life threatening asthma and anaphylaxis. The allergens that the Canadian Food Inspection Agency require to be effectively controlled within food facilities are the following:

Egg, Dairy - Milk and milk ingredients, Wheat, Gluten, Soy, Fish / Crustaceans / Shellfish, Peanuts, Tree nuts, Sesame, Mustard and Sulphites at a level >10 ppm.

The allergen management program needs to outline how you will identify and control:

1) upon receiving and storing

2) ingredients and product through the processing

3) of packaging and labelling

By maintaining allergens and non allergenic ingredients separately during receiving, storage, processing and shipping and scheduling all allergenic products at end of day or end of week will assist in the control of your allergens.

The second action is to ensure that all transfer equipment - scales, buggies, carts, racks, scoops etc. are kept for the allergen products. A few ways that this can be done would be to colour code them or tag them so that they can easily be identified which allergenic products it is being used for.

Special care will likely need to be taken around the ovens and cooling if they are found within your process as this is often where multiple products are kept together prior to packaging.


Packaging and labelling is important as this is where employees will need to ensure that the right package or label is applied to the product. You may have two products that are extremely close in visual appearance but one contains an allergen and the other doesn't. (i.e. regular hot dog, hot dog stuffed with cheese). Therefore, you should ensure that you have checks and balances to ensure the right label is getting onto the correct product. Removing packaging from the floor prior to converting to a new product helps to ensure that incorrect packaging isn't accidentally placed on the wrong product.

This step starts, however, when the labels are developed to ensure that all allergens are included on the label. Therefore, strong relationships with your suppliers is important to make sure you always have correct specification / ingredient information. Then, it is important that you take great care during the creation of the new label to ensure that all allergens are included on the label. You also need to review your process to determine whether you can effectively eliminate all allergens. If you can't then you do need to use a may contain statement. For example, in a bakery where sesame seeds are being used, it may not be possible to ensure 100% elimination of this allergen and therefore you would need to put this on the label as a "may contain sesame" statement.

By effectively maintaining and controlling allergens along with strong management of your labels and labeling program you can keep your name off the "Undeclared allergens" recall list. Just one more way to maintain brand integrity.


For many of you, you will already have a HACCP program in place which already outlines the Preventive control programs that you have in place. However, for some of you it may mean the implementation of a Preventive Control Program.

CFIA has constructed templates to assist manufacturers with the development of this program, which is essentially a condensed version of HACCP. You, as a manufacturer, will be required to review all of the hazards that are associated with your ingredients and processes and determine measures needed to control these hazards. Once you've identified the hazards that are not fully controlled within your facility you will put together procedures to effectively control them. It may include GMPs, Training, maintenance, sanitation, allergens.

These programs work together to ensure that you will greatly reduce the potential for bacterial contamination to occur within your plant. Bacterial contamination such as E.coli, Salmonella or Listeria monocytogenes can be introduced through your plant, process or your people and anywhere where these three things come into contact with your product.

Strong compliance to your preventive control programs will allow a facility assurances that these “bacterial” recalls won't happen to you. Looking back you can see that these can happen to any facility and therefore it is important that you are vigilant with these programs. By instilling a food safety culture from the top all the way down to each of the plant employees help to ensure the programs documentation are being followed accurately and effectively.


Traceability is critical for consumer safety and is also a requirement of the new Safe Food for Canadians Act. These new regulations require all manufacturers to have a program that will have the ability to trace a product backwards to its supplier and forwards to the retailer and will need to have clear and readable records that show this. Retailers will also need to be able to trace product back to their original vendor. These traceability records will need to be maintained for a minimum of 2 years and you would are required to be able to conduct full traceability in under 4 hours

In the recent outbreak with E.coli in flour it was critical for many manufacturers that used this flour to be able to trace the ingredient in all of their products to determine the particular production containing the affected flour. By ensuring a strong traceability program they could minimize the recall to ONLY the product that was affected. and by removing it as quickly as possible reduce the potential that a hazard reaches consumers and potentially makes them ill.

Most accounting or ERP programs are extremely helpful with traceability program and have the capability to trace ingredients from purchase through manufacture and through to retailers. But no matter what your size you can put measures in place to ensure that you can trace your product.

Strong traceability / recall program

A well written Operating procedure outlining:

1) how you trace ingredients and packaging and how you trace finished products.

2) recall team and the responsibilities of each of the team members

3) template forms that can be used in case of an actual recall i.e. Notice to Vendors, Letter to CFIA, Tracking recalled products, etc.

4) CFIA contact information & other potential relevant contact information. e.g. laboratory services

In addition, you should test your program, at a minimum annually, to ensure that it is working and you can easily trace your product. This ensures that all team members are well versed in their responsibilities and that the program is functioning effectively.


Prevention and preparation for food safety within the key concepts.

The Government of Canada has adopted a new regulation called the Safe Food for Canadians Act. This is to make our food safety system stronger and ensuring greater consistency within food inspection and enforcement. With all manufacturers following these new regulations Canadian Manufacturers and CFIA can ensure that we are being proactive in Food safety, capturing the main “Recall issues” that are witnessed year to year and have the preventive programs in place to control these potential issues.

We've already reviewed two of the main changes above: Preventive control programs and Traceability & recall program.

The other main change is the licencing component. Under these new regulations, all manufacturers who import, manufacture, process, export food and those who slaughter, store or handle meat products will need to have a license to continue with their work. Many Ontario regulated facilities may not need to obtain a licence until 2020 with meat, dairy and importers are all on a much earlier timeline and will most likely need their license by Jan. 15 / 19. It is important that you determine the timing that your company needs to follow. This can be done by heading to the following CFIA website, https://na1se.voxco.com/SE/93/SFCR_licence/?&lang=en where you can determine what date you require a license.

By looking at the past you can view what potential risks lie in the future. You can further build on the food safety programs that will best enable you to reduce or greatly eliminate the risks. FS & RD Consulting can assist you with navigating through any of these food safety programs and improve any programs that you have in place. Check out our website at www.fsrdconsulting.com or give me a call for a free quote.

Melissa Stevenson