Risk management

Risk management is about eliminating or reducing the risk of unintentional presence of allergens including cross-contact and incorrect labelling.

Factory supervisor in sterile clothes standing in food factory and looking at tablet.Allergens need to be managed from the very beginning; starting with product design all the way through the production process to the finished product.

This section covers the important areas to consider in risk management of food allergens. We also provide a checklist which may help you as a food producer to evaluate your procedures for allergen control and to improve them.

Employee training and supervision

Training and supervision of all staff is essential to avoid unintentional presence of allergens in products and incorrect labelling. All staff need to be aware of how important their role is in protecting allergic consumers.

The Foods Standards Agency’s food allergy online training

The Food Standards Agency (UK) has developed free online training material for their enforcement officers, but food business owners are also invited to use the material to train employees.

Controlling Food Allergens in the Plant training programme

The Food Allergy Research and Resource Program at FARRP) at the University of Nebraska-Lincoln have, together with Silliker Inc., created paid-for training materials for employees in food production facilities. This material includes a video and written guides.

Think On… training programme for factory employees

This programme was originally designed by Nestlé for factory employees in Germany. It offers basic training on the control of food allergens and food allergy. EuroPrevall has made minor changes to the version provided by Nestlé. The three training sessions, feedback-sheets and a short instruction how to perform the training sessions can be downloaded below as PDF files.

Product design and formulation

Whenever possible it is good practice not to include an allergenic ingredient in a product unless it is necessary.

Some questions that a manufacturer or food formulations expert needs to consider are:

  • Is a specific allergen essential to the functionality of your new or reformulated product? Could an alternative ingredient be used?
  • Is the allergen already handled at the facility where you plan to manufacture the new product? Could you manufacture your new product at a facility where the allergen is already handled? 
  • Are people who you target your new product towards likely to be particularly sensitive to a specific allergen (e.g. geographical differences or differences between children and adults)?

What is the risk of allergen cross-contact to other products if you introduce a new product on an existing or a new production line?

Supply chain of raw materials

You need to establish appropriate procedures to assess the allergen status of food ingredients for use on your premises.

You may do that through supplier audits or questionnaires to your suppliers. Some questions that you may consider to ask your suppliers are:

  • Whether an ingredient contains any food allergens either as a major component, a minor component or due to cross contact.
  • How your suppliers manage food allergens.
  • To notify you of any changes in the allergen status of the ingredients they supply.

You can access an example questionnaire from the Australian Allergen Bureau.

Manufacturing premises, equipment and processes

The ideal approach to avoid cross contact with allergens is to dedicate production facilities to specific allergenic products but this is not always an option, particularly in small businesses.

The key to manage cross-contact with allergens in such a situation is to find ways to separate the production of allergen-containing products from those that do not contain the allergen. Some questions that you may consider are:

  • Is it possible to store ingredients with different allergens in clearly identified areas?
  • Is it possible to have dedicated production lines or areas?
  • Is it possible to erect physical barriers and/or separate the air supply between production lines or areas?
  • Is it possible to minimise the movement of material and personnel between production lines or areas?
  • Is it possible to dedicate utensils and equipment?
  • Is it possible to design equipment to minimise cross contact?
  • Is it possible to schedule production runs to minimise possible cross contact (allergen after non-allergen)?
  • Is it possible to clean between production runs with allergens and non-allergens?
  • Is it possible to manage re-work that contains an allergen to ensure that it is only re-worked into a product that already contains the allergen?
  • Is it possible to label held-over products and unused packaging material in a suitable way? 

If it is not possible to separate products with and without allergens adequately you need to assess the risk of allergen cross contact and if appropriate use advisory labelling.


Documented and validated cleaning procedures are critical to avoid allergen cross contamination.

You need to seek out and inspect all the trouble spots. Cleaning practices that are satisfactory for hygiene purposes may not be adequate to remove all allergens. Equipment may for example need to be dismantled to remove allergen residues. A tool you can use to validate your cleaning is to test for allergen residues. 

Many test methods are commercially available for food allergen analysis. Most of the analyses are immunochemical methods such as ELISA but DNA-based detection based on polymerase chain reaction (PCR) is growing in popularity. However, the development of analytical methods to detect levels of allergens is still at an early stage.

The EU has not yet agreed independently validated methods for all the allergens for which ingredient labelling is required. The kits that are currently available may vary in how sensitive and specific they are. They may also vary in how effective they are to analyse different food materials.

At the moment you can therefore choose to validate your cleaning procedure by looking thoroughly at the production line after cleaning.

If it is not possible to clean your production line adequately you need to assess the risk of allergen cross contamination and if appropriate use advisory labelling.

Further reading on analytical methods

Packaging and labelling

Incorrect packaging and/or labelling causes the majority of the allergen-related product recalls.

In order to ensure accurate information to your allergic consumers you need to implement procedures to check that your products end up with correct labels.

Some areas where you may minimise the risk of applying incorrect labels are as follows.

  • Checks should be in place between processing and packaging.
  • Check labels during product run.
  • Destroy old packaging when you need to use new packaging following a recipe change or new allergen cross contact risk.
  • Be sure to remove all packaging at the end of a run.
  • Be sure to use the correct outer packaging for multi-pack products.
Checklist for allergen control in food production

Consumers expect and demand all food handlers to have the knowledge and insight required to supply safe food of high quality.

As a food producer you should read and understand relevant national guidelines on food allergy. You need to gain insight on what you can do to supply safe food to allergic consumers.

The purpose of this checklist is to help you as a food producer to evaluate your procedures for allergen control and to improve them. If you change the allergens in a product or the production process, you need to re-examine the procedures in the checklist in order to ensure that no mistakes occur.

The checklist was translated and slightly adapted in June 2008 from an appendix in the Swedish Food Sector Guidelines for Management and Labelling of Food Products with Reference to Allergy and Intolerance.