Adjusting your practices for the new FDA-added allergen: sesame.

As of January 1st, 2023, the Federal and Drug Administration (FDA) added sesame to the list of major food allergens in the United States.

Regulatory changes are not things to take lightly in any industry, and food processors are not an exception. Changes in regulations and industry standards bring additional stress to executives, leaders, and staff, so we are here to alleviate part of that feeling with some practical advice.

Let's take a look at what that means to your business and the people in your organization.

A few interesting facts about allergens and sesame.

Allergen control has been a topic of strong focus by regulatory and industry agencies. It is nothing new to food processing, and there is research and reasons behind it worth citing. JAMA Network Open published on January 4th, 2019 that an estimated 10.8% of US adults were food allergic with still many unknowns on prevalence, severity, and health care. 

When it comes to the newly major allergen-added, sesame, an investigation published by JAMA Network Open in August 2nd, 2019 found that an estimated 0.23% of the population in the US had a convincing sesame allergy, therefore the efforts to reduce the public health burden.

It can be expected that the more we learn, the stricter the requirements for food handlers will become to protect consumers and public health. 

With all this, in what food may you commonly find sesame? your morning bagel, your hamburger bun, the sushi you had for dinner, the dressing in your salad, and others such as sauces, cereals, snacks, and protein bars, just to name a few. 

Enhance your food safety culture

a) A good onboarding makes a difference. Use this moment as an opportunity to show and invite your new team members to partake in their corresponding food safety practices and understand the importance of how that translates to consumer confidence. You may be surprised how this commitment contributes positively to your employee retention rates.

b) There is always room to improve communication. Besides, most of us like to learn something new, so here are a few ideas.

• Ask your food safety practice leader to research a few interesting facts about sesame: in news, from recipes, some statistics, stories, etc., and share them once a month during your daily stand-ups.
• You can also use any displayed screens in the lunchroom and staff areas to share these interesting facts.
• You can also use your communication boards to post some challenges and prizes! E.g. you can ask them to share a picture of a product at home or at the supermarket where sesame is listed as an allergen. The first “X” number of employees that find sesame in the “contains section” of the label get a gift card..

Update of food safety programs

1. Work with your purchasing and food safety teams on requesting new allergen statements from suppliers and identify, address and update supply chain risks. Identified risks may trigger changes in other programs (e.g. updates needed in HACCP, labels, vulnerability assessments), but first steps first.
   
   
2. Make sure any allergen control and related training materials are updated. What used to be known as “the big 8” are now “the big 9”. You can use this opportunity to make training materials more effective, by introducing fun and interactive activities: e.g. have attendees identify all allergens from their last lunch or dinner, share real stories from friends, family and/or the news.
   
   
3. Work with your food safety leader and team to update: the allergen program, risks assessments, and allergen signage throughout the facility.
   
   

What if sesame is on the list of ingredients but is not used on all your products or maybe it is? Then you need to ensure you address all the associated risks.

Raising awareness is also key if you handle sesame. The same awareness advice applies to you, now there is more to consider.  

Make changes a team effort

What does top management need to do?

1. Use your next management review to request the team to check and update practices for compliance.
2. Request the leader and team a plan and status updates.
3. Support the team with decisions that may need to be taken for compliance.
4. Support the team with expert or legal advice.

What does the R&D team need to do?

Check that labels and product specs of products with sesame are up to date and meet FDA labeling requirements.

What do food safety practice leaders need to do?

Check for potential risks on food safety plans, assessments, zoning, and protective clothing, utensils and color codes, GMPs policies and inspections, testing program, validation program, look for old labels, and if needed adjust documentation and practices. 

What does your purchasing team need to do?

work with the food safety team to ensure compliance requirements, and work with suppliers to update supplier packets.

What does your warehousing team need to do?

Asses and redefine materials and product flow, and allergen zoning to reduce the risk of sesame cross-contamination.

What do operations teams need to do?

Check for cross-contamination risk from production planning, operations sequencing, changeovers, and product label control.

What does your sanitation team needs to do?

Check for cleaning effectiveness after sesame.

What does your HR team need to do?

Check and update onboarding and training materials.

What does your customer service need to do?

Be prepared for any questions or inquiries from customers (and potential customer complaints) on label changes.

Reward the team effort

Implement a monthly or quarterly recognition program and bring top management, middle management and operational teams together to snack, share accomplishments, and keep staff informed on ongoing changes and updates. Fun team activities like games and challenges can be a good addition to these in-person or e-gatherings. You can also invite team leaders to share how their team has come together to achieve a common goal.

You can also reward overperforming teams with out-of-the-office experiences to encourage teamwork and motivation.

Do you need an extra set of eyes?

At London Consulting Group we are happy to use our proven methodology to address your business needs.

We listen: we will talk to your leaders to get a high-level understanding of where the organization is in terms of compliance.

We discover: we will spend a few hours on-site with your team and inspect documentation and practices impacted by the introduction of sesame as a major allergen. We will provide practical recommendations to minimize risks and ideas on how to streamline, and yet have an effective food safety system.

We transform: do you and your team need help to make changes happen? We will support your team with project management, digital transformation, documentation, training, and shoulder-to-shoulder implementation, toward improving food safety practices and operations.

Author: Marlene Kellenberger

These FDA updates are a good read:

https://www.fda.gov/consumers/consumer-updates/allergic-sesame-food-labels-now-must-list-sesame-allergen#:~:text=As%20of%20January%201%2C%202023%2C%20sesame%20is%20required%20to%20be,milk

https://www.fda.gov/food/cfsan-constituent-updates/fda-reminds-manufacturers-effective-date-sesame-major-food-allergen