Why Allergen Management Failures Keep Happening
The Food Standards Agency issues allergen-related food alerts consistently — year after year, the same categories of failure appear: undeclared allergens on labels, cross-contamination during production, supplier mislabelling of ingredients, and rework added to products without allergen reassessment. These are not novel failure modes — they have been understood for decades. They persist because allergen management is treated as a compliance exercise rather than a quality management discipline.
BRCGS Issue 9 and FSSC 22000 Version 6 both strengthened allergen management requirements significantly. The certification standards now require demonstrated effectiveness — not just documented procedures. An allergen management programme that exists on paper but has not been validated through cleaning validation, verified through label checks, and tested through challenge exercises does not meet current certification requirements.
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