Individuals with food allergies and their caregivers rely on nutrition labels and ingredient lists to ensure that packaged foods don’t contain their allergens. Manufacturers work hard to provide clear and accurate information. Yet, sometimes there are still questions or confusion.
As a parent of a child with a food allergy, Kevin Boyd, PhD, DABT, Manager Allergens and Toxicology at The Hershey Company, brings a unique perspective to bridging the divide between consumers and manufacturers when it comes to allergen management. We sat down with Kevin to learn more about how he and the team at Hershey approach this important topic.
NPB: Tell me about your role at Hershey.
KB: My role at The Hershey Company is really twofold: I am a toxicologist by training and am involved in aspects of food safety and regulatory affairs, but I also have responsibilities for the corporate allergen programs and spend a lot of my time on the allergen side. This gives me a chance to drive higher level strategies and directions for our allergen program, but the actual “allergen management” involves everybody across all functions at Hershey and throughout our supply chain. Writing great-sounding standards and practices is the easier part; translating that into effective execution during manufacturing is the key. Luckily, we have a strong emphasis on our food safety culture and terrific people throughout the company focused on producing products that our consumers can trust.
NPB: What are some keys to safely handling food allergens in manufacturing facilities?
KB: If you boil down allergen management as simply as you can, you’re really just trying to do two things: 1) don’t have allergens in products where they are not supposed to be, and 2) put the right product in the right package (with the right information).
In practicality, however, there’s a lot that goes into achieving these two objectives. Any time you manage multiple allergens in a facility or share equipment with products that contain different allergens, you are introducing situations that must be effectively managed. This starts with a strong supplier quality program and understanding the allergen programs and controls of your ingredient suppliers to mitigate risks throughout the supply chain. Then you need to critically evaluate your facility, equipment, and the allergens you are handling from all angles (labeling, storage, segregated areas, color coding of utensils/bins, cleaning, transport of materials, traffic patterns, etc.). Similar to consumers who may choose to avoid shared equipment with their allergens, food companies would also prefer not to share equipment; unfortunately, that is typically not feasible (unless that is the market focus of a company). I always think of those insurance company commercials where they say: “We know a thing or two because we’ve seen a thing or two.” That is the same for companies that have a lot of experience managing allergens, such as Hershey.
We have strong programs in place, and we have learned how to effectively manage allergens from all of those experiences, but production is a dynamic process so you’re always looking for opportunities and tweaks to continue to improve and strengthen your allergen management programs. This is also very much like when you first receive a food allergy diagnosis. You can feel lost and overwhelmed, but as time goes by and you begin to navigate life with a food allergy, you develop a system. Of course, that is not the end; you constantly learn and evolve.
NPB: Of course, peanuts and tree nuts are common allergens people think of when it comes to food allergies, but Hershey products include many allergens. Is there a difference in the way you handle peanuts and tree nuts as compared to other allergens?
KB: Just in general in society, people hear a lot more about nuts, peanuts in particular, but consistency and clarity is important for everyone across our organization so we handle all allergens in our facilities similarly and do not give certain allergens higher priority than others. We do account for the various forms of allergens in terms of management and processes that need to be in place (e.g., powders, dusty materials, mixed into a solid/thick form etc.). In addition, there are different regulated allergens around the world; so, as a global company, we must be aware of what those allergens are and where products are intended to be sold.
NPB: Precautionary labeling is not required or regulated by FDA. How do you decide when to use PAL?
KB: This is a great question and a topic that is quite complex when you really start thinking about all of the nuances that can make the “same” situation very unique; particularly if you couple this with different consumer preferences/comfort levels and with challenges in conveying all of the details about a product at the point of purchase.
As a simple example, if all allergens used in a facility were identified on a label as “processed in a facility that also processes X”, a situation in which lines are side by side (which may or may not pose an appreciable risk of cross contact itself) would not be able to be distinguished from a situation in which lines are at opposite ends of a football-field-sized building with walls in between the different production areas. There are really no “one size fits all” tenets, and there are numerous factors that have to be evaluated for each facility, equipment, and specific process.
Therefore, deciding when to use precautionary allergen labeling is a case-by-case decision that requires a thorough understanding and evaluation of the total manufacturing facility and production process. This means that we are not automatically adding statements for all allergens used in a facility, for example, as we reserve precautionary allergen labeling to provide meaningful information and identify those products that consumers with the specified allergens should avoid as they may sporadically contain low levels of the indicated allergens due to unintentional and unavoidable cross contact.
In situations where consumers would like additional information, however, we work to provide them with answers so that they can make informed choices within their comfort level.
NPB: You are also the parent of a child with food allergies, what advice do you have to parents about reading labels for food allergies?
KB: I wish I had the magic answer for folks. Obviously, always read the entire ingredient statement. We hear from a lot of consumers who think that the “Contains” statement is mandatory, which is not the case. If a company chooses to use a Contains statement, then all of the allergens declared in the ingredient statement have to be declared again in the Contains statement, but the absence of a Contains statement does not mean that there are no allergens in the product. Then, everything else is really about your family or personal plan and each individual or family’s comfort level. Although managing any allergy/allergies can be challenging, I really feel for the folks who are managing non-top 8/non-major allergens.
NPB: Is there anything else you would like people to know about food allergen management in manufacturing?
KB: For me personally, the transition from consumer/parent of an allergic child to joining The Hershey Company and moving into the food industry has been really fascinating. There is a lot of work that the food industry puts into allergen management that I definitely did not fully appreciate solely from the consumer lens. I am willing to bet that all of us have eaten or even routinely eat products that are riskier than others we intentionally avoid.
We have this interesting dynamic where food companies know their processes the best, but we as consumers have a hard time trusting them. We as food companies should be transparent and answer consumer questions, and as consumers it’s good to have a healthy level of skepticism, but we really need to find some ways to bridge this divide. Communicating with consumers on specific details, however, is not always as simple as it sounds as every scenario can be different (e.g., many assume shared equipment is higher risk than shared facility but that is not automatically true, the details are important).
There’s a quote I really like about all of the information we have access to today with advances in technology, and that is: “It has never been easier for people to be wrong and at the same time feel more certain that they are right.” One of the facets of living with food allergies that makes life so tricky is the uncertainty and unknowns. There’s a lot of great information out there, but there is also a lot of misinformation; therefore, my best advice is finding a comfort level that works for you and your family and sticking with that.