Dealing with Allergen Related Consumer Contacts from a Manufacturers Perspective

1. Dealing with Allergen Related Consumer Contacts from a Manufacturers Perspective

2. Allergens in our plants • Wheat and gluten • Dairy • Eggs • Sesame • Tree nuts • Peanuts • Fish

3. Goodman Fielder Policy • Food allergens are a serious food safety issue • Food manufacturers are responsible for the control of food allergens and for accurate information Principal strategies to deal with allergens: • GMP • Full integration of allergen hazards in the HACCP studies • Appropriate labelling of products

4. Labelling Policy • Our current policy is to eliminate allergens where practicable through reformulation or substitution • Allergenic ingredients are bolded in the ingredients list • Warning statement near the ingredients list highlights the allergens in the ingredient list “ contains…………. • Validated controls such as cleaning, isolation, segregation etc • Labelling can only to be used when we can not guarantee that there will be no cross contact – eg sesame

5. Consumer Contacts • 187,452 consumer contacts since March 2001 • 317 (0.17%) of these were general inquires relating to allergens

7. Advisory Statement • Since 01 March 2001 we have recorded 3 inquiries regarding the meaning of our cross contamination statement • “made on a plant that also produces products containing ………”

8. Allergic Reactions • 7 contacts (since March 01) claiming allergic reaction after consuming one of our products • Of these 5 had known allergies • Methyl bromide - not used in any ingredient or process unable to identify source or cause • Mushrooms – not used in product or on site, however product does contain vegetables, supplier unable to confirm that there would be no contact with mushrooms • Eggs – consumer had an allergic reaction similar to her egg allergy after she ate a plate of porridge oats, eggs are not used on the manufacturing site or anywhere in the chain from the farm to the pack that could be identified, no trace of egg in retained sample. • Wheat – not used in the specific product but used in other flavours of that product – possible cross contamination at site level – processes reviewed and tightened. • Child had multiple allergies and reacted after consuming a pack of crisps – not confirmed but suspect a pack of incorrect product may have found its way into a multi pack.

9. Allergic Reactions • Allergic reaction to Organic Bread • Consumed half of the loaf prior to onset of symptoms, did not have a known allergy to any of the ingredients and could not remember what was consumed with the bread. Bread had been in the freezer and there was no retained sample • GF Investigation • Limited due to lack of sample and time lapse between manufacture and consumption (6 weeks) • Checked production records, investigated ingredients with suppliers, no issues identified. • Consumer contacted and advised

10. Dealing with Unlabelled Allergens • Own label produced by two manufacturers • Different formulations used in South Island vs. North Island product. • Packaging identical other than ingredients panel and bar code • Supplier mix up of packaging resulted in product containing milk being packed in unlabelled packaging distributed in the North Island.

11. Dealing with Unlabelled Allergens • Actions • Stop production • Stop distribution and pull stock from supply chain • Advise key account contact • Risk assessment – • 2 batches, issue picked up at store level when product barcode failed to scan • Limited distribution • Short shelf life, does not freeze well • Product on promotion so possibility of new consumers • Outcome decision to initiate consumer level recall • Allergy NZ and NZ Therapeutic Database advised • Media advertising commissioned • Recall undertaken. • Preventative actions • Policy in place to prevent split manufacturing (standard formulations in place across NZ) • Barcodes on packaging checked at inwards goods.

12. Summary • Goodman Fielders strategy is to provide safe food with informative labels for allergic consumers • The need for precautionary statements is minimized • We provide information for consumers to via our Consumer Advisory Centre. • The actual product label with the ingredient list is THE key information • All allergen non conformances are rigorously investigated and product is recalled if the risk is unacceptable. • The consumer must take final responsibility for the management of their allergy • Prevention of incidents: combined action of allergic persons, food producers, restaurants, caterers, doctors, food authorities • Communication must flow among involved parties • Awareness is not enough - all involved parties must also have the right attitude