Envisioning 2022 Food Safety and Sanitation Expectations

We began 2022 with a renewed hope for better health, safety, and progress for all. Food safety management across our global supply chain, from farm to fork, is a priority that cannot be ignored as a large piece of that hope. Last year, as we celebrated 10 years of U.S. FSMA in the thick of a continuing COVID-19 pandemic, we saw sesame recognized as the 9th Top Allergen in the U.S. and a major nationwide recall of imported fresh onions towards the last quarter.

This year, we should expect to see some more food safety and sanitation-related progress in the U.S. and global food supply arenas, especially within the following areas:

  1. Greater Emphasis on Data Analytics and Information Sharing: Risk-based food safety decisions across food sectors will become more data-driven and based on real-time. More importantly, FDA’s New Era of Smarter Food Safety (1) approach has recently been initiated by stakeholders – this collaborative platform intends to leverage innovative technology and newer processes to help create a safer, more digital, and traceable food safety system.
  • Better Innovative Controls through Continuous Collaboration: Besides having a science-based research and policy on Salmonella reduction (2) in FSIS-regulated products, there will be an increased drive towards implementing modernized controls and newer technologies for reducing pathogens, especially in raw meat and poultry products.
  • Moving Ahead with an All-Inclusive One Health Vision: To get to the root source of food contamination, food safety and sanitation expectations will have to increasingly function under a multisectoral, One Health framework. (3) These efforts should work seamlessly at local, regional, national, and global levels with the goal of sustaining a positive public health outcome by recognizing the interconnectedness between people, animals, plants, and their shared ecosystems.

In the world of food safety standards and regulations, the following developments are expected:

  • British Retail Consortium Global Standards (BRCGS) Food Safety Standard Issue 9 is expected to be published around August 2022, and audits to the newer version are expected to start from February 1, 2023. Stay updated with recent changes through the BRCGS website. (4)
  • For those in the Produce Sector, listed below are all the FSMA Rule Requirement compliance date deadlines. (5)
FSMA Rule RequirementCompliance Date Deadline
Produce Safety Regulation – Very Small Farms, Remaining water requirements for Other ProduceJanuary 26, 2022
Produce Safety Regulation – Large Farms, Non-sprout agricultural water requirementsJanuary 26, 2022
Produce Safety Regulation – Small Farms, Non-sprout agricultural water requirementsJanuary 26, 2023
Produce Safety Regulation – Very Small Farms, Non-sprout agricultural water requirementsJanuary 26, 2024

The Produce Safety requirements are important especially when numerous recent food-illness outbreaks have been sourced to pathogen cross-contamination at the farms. For updated information on FSMA Compliance Dates, visit the FDA’s website.

Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene, and material handling equipment, is here to assist our customers with their site’s food safety and sanitation expectations. For more information, contact us.


  1. New Era of Smarter Food Safety | FDA
  2. USDA Releases Roadmap to Address Salmonella | Food Safety and Inspection Service
  3. One Health | CDC
  4. Issue 9 Revision | BRCGS
  5. FSMA Compliance Dates | FDA

Looking Back at 2021: A decade of FSMA, a new allergen, and updated guidelines

This year marked a decade since the FDA Food Safety Modernization Act (FSMA) came into effect as a means to facilitate preventive control interventions and lower foodborne illness outbreaks. Of course, despite the food industry’s primary focus being on managing employee safety and handling supply chain logistics during the ongoing COVID-19 pandemic, food safety still featured as one of the essential consumer-centric requirements from regulatory, standards, and industrial initiative perspectives. 

The following highlights some key food safety-related developments that happened in 2021: 



April 23, 2021 

The Food Allergy Safety, Treatment, Education and Research (FASTER) Act was signed into law, which adds sesame to the existing list of Big 8 major food allergens (joining milk, eggs, fish, shellfish, tree-nuts, peanuts, wheat and soy). This means that sesame must be labeled on all regulated packaged foods by Jan. 1, 2023. 

May 24, 2021 

The SQF Edition 9 Food Safety Codes, one of the GFSI Benchmarked global programs, became an auditable version standard. There is an enhanced focus on cross-contamination prevention and hygienic design, among other version improvements. 

July 2021 

New FSIS Guidelines for Controlling Salmonella and Campylobacter Bacteria in Raw Poultry were issued, which also relate to sanitation and HACCP requirements in poultry establishments. (It’s important to note: According to the CDC, Campylobacter and Salmonella are the #1 causes of bacterial foodborne illness outbreaks in the U.S.). 

September 2021 

The Retail Food Safety Association Collaborative launched an interactive U.S. Food Code Adoption Map. Through this collaborative platform, agencies such as the FDA and CDC, among others, will work together to reduce incidences of foodborne illnesses in the retail food establishments. (Note: Over 60% of U.S. food illness outbreaks are related to food retail and foodservice establishments). 

October 2021 

The first ever New Era of Smarter Food Safety Summit on Retail E-Commerce Foods was organized and well-attended by the FDA, other U.S. agencies, industries, academia, and stakeholders from about 49 countries. The panel and public discussions were centered around cross-contamination prevention strategies during food delivery, among other food safety control interventions. 

October – November 2021 

multi-state outbreak of Salmonella Oranienburg involving whole fresh onions were traced to a farm in Mexico. As of November 12, the CDC reported there were 892 illnesses in 38 states and territories. The FDA recommends that anyone who received, or suspects having received recalled onions use extra vigilance in cleaning and sanitizing any surfaces and containers that may have touched these products to reduce the risk of cross-contamination. This includes cleaning and sanitizing cutting boards, slicers, countertops, refrigerators, displays, and storage bins. 


Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene, and material handling equipment, appreciates and fully supports the role of the food industry and the front-line workers in assuring food safety and sanitation.  

 We earnestly look forward to a healthy, prosperous, and stable 2022 for all. Meanwhile, we wish everyone happy holidays and a safe season! 


New Era of Smarter Food Safety Summit Focuses on the Crucial ‘Last Mile’: Foods Ordered Online and Delivered Directly to Consumers

New Era of Smarter Food Safety

Remco is proud to have participated in the FDA’s New Era of Smarter Food Safety Virtual Summit on E-Commerce that took place from October 19-21, and which was well attended by regulators, industry representatives, and consumer groups from about 49 countries. Participants gave the agency information, asked questions, and submitted public comments to help them understand the challenges and solutions regarding food safety through a B2C ecommerce model. To this end, they also helped deliberate on the FDA’s New Era of Smarter Food Safety Blueprint Core Element # 3 on ‘Business Models and Retail Modernization.’ 

According to Partnership for Food Safety Education, during the COVID-19 pandemic there has been an over 300% increase in online ordering and grocery delivery/pickup, as well as substantial growth in meal kit sales, and this trend is expected to persist once the pandemic and economy stabilize. Key food safety threats in such B2C e-commerce food delivery systems can include: 

  • Temperature-time abuse of perishable and frozen foods 
  • Package tampering potential and labeling issues 
  • Sanitation and employee hygiene during preparation 
  • Cross-contamination of food during delivery, etc. 

The discussions revolved around whether an improved regulatory oversight framework was required in the technologically innovative and consumer-centric e-commerce market. Industry and consumer viewpoints were also considered. Additionally, international regulators from Japan, Brazil, England, Wales, and Germany also presented their perspectives on their B2C e-commerce food markets. Dr. Andreas Keller, Director of Multi-Commodity Foods at FDA CFSAN, aptly put it in part of his closing remarks: “The challenges we face [for B2C delivered foods] in the U.S. are similar to those faced in other countries, highlighting the need to collaborate and exchange information on how best to ensure the safety of these foods globally.” 

The FDA has requested formal comments on B2C e-commerce delivered foods from the public, with the details are available here. Remco has supported the FDA’s New Era of Smarter Food Safety Initiative ever since its inception and blueprint development by participating in forums, contributing to discussions, and providing comments that help in bending the curve of foodborne illness in the U.S. and globally. We share this vision of promoting smarter food safety by providing the end-users with high-quality color-coded material handling tools like scoops, tubs, scrapers, mixing paddles, and much more. As a Vikan company, we also distribute innovative, hygienically designed cleaning tools and solutions (e.g. brushes, brooms, squeegees, etc.) to food producers and manufacturers based in North America. For more information about our products and services, contact us.




IAFP 2021 Emphasizes Food Safety & Sanitation from Farm to Fork

Neither the heat nor the hybrid-nature of the conference amid the pandemic could stop food safety professionals from attending IAFP 2021 on July 18 – 21 in the beautiful city of Phoenix, AZ. Regulatory, industry, academia, and advocacy groups participated online and in-person while effectively contributing towards the organization’s mission of “Advancing Food Safety Worldwide.” 

The customary Ivan Parkin Lecture was delivered by Dr. Robert Gravani, Professor Emeritus of Food Science at Cornell University. He aptly emphasized creating a learning culture among company employees to raise the bar on food safety. During the presentation, we were honored to have our Remco IAFP 2019 poster mentioned, including our finding that: “…one-third of FDA food product recalls from 2008-2009 were clearly related to cleaning and sanitation, hygiene, and material-handling practices.” 

The conference agenda also included symposia sessions, technical presentations and posters, roundtable talks, and exhibit booths organized by various stakeholders representing the farm-to-fork food supply continuum. Some of the key engaging topics of interest were on: 

  • Fresh produce safety challenges in the U.S. market and continuous improvement initiatives. 
  • Innovative dry-cleaning and sanitation strategies for low aw food processing facilities. 
  • Traceback challenges and opportunities in recent Listeriosis outbreak investigations. 
  • Using the Root Cause Analysis tool for investigating and preventing contamination incidents. 
  • Allergen management controls at grocery chains and foodservice outlets, etc. 

This year also marks the 10th anniversary for the U.S. Food Safety Modernization Act, which was enacted into law on Jan. 4, 2011. This sweeping reform shifted the FDA’s focus from mere reactive food safety interventions to a proactive mode of preventing food contamination incidents and bending the curve of foodborne illnesses. Celebrating the first year since the launch of the New Era of Smarter Food Safety blueprint, FDA Deputy Commissioner for Food Policy and Response Frank Yiannas made it clear: “…we aren’t walking away from FSMA, but that through the New Era initiative, we would want to facilitate the adoption of smarter technologies, flexible and feasible prevention-based models by industry, with people-led food safety culture in mind.”  

 In a nutshell, the conference theme was well put forward by Barbara Masters during her John H. Siliker Lecture presentation. Drawing from the challenges and experiences in helping come up with FSIS Salmonella performance standards for reducing contamination in raw meat and poultry, her takeaway message was equally resounding: “We are all working together on the same puzzle!” 

Remco also presented a poster on a new risk model that may be used for effectively planning food safety hazard management controls for the food industry. The presentation was well received by the audience, especially regarding the addition and accountability of detectability and controllability hazard elements.  Besides, as a leading manufacturer and supplier of FDA-compliant, color-coded, and durable cleaning and material handling tools for food facilities and other hygiene-sensitive environments, we are proud to have consistently participated as a gold sustaining member and exhibitor at the conference. For more information about our products and services, contact us. 

About IAFP: International Association for Food Protection (IAFP) is a member-based association of more than 4,500 food safety professionals committed to Advancing Food Safety Worldwide® by providing food safety professionals worldwide with a forum to exchange information on protecting the food supply. More information is available at: https://www.foodprotection.org/ 

Raising the Bar with Hygienic Design: 3A and Showcasing our Next Generation Remco and Vikan Tools

Investing in a “hygienically designed” facility, equipment, or an itemized inventory is no longer just a buzzword for the food and beverages industries. Having surfaces that are easy to clean, inspect, and access have become definitive hallmarks for ensuring sanitary production of safe food by preventing or significantly minimizing key environmental hazards (such as pathogens, unique allergens, and deleterious foreign material) from contaminating food.   

Of course, design is considered an integral part of the material specifications that’s critical to assuring environmental and food sanitation. Last month, Remco attended the 3-A SSI’s 2021 Virtual Conference (a) where regulatory sanitarians, equipment manufacturers, food industry processors, academics, and professionals collectively deliberated on the “role of hygienic design in improving food safety plans.” Some topics of interest covered during the session were on: 

  • Pathogen control strategies  
  • Developing hygienic design training for the staff
  • Avoiding pitfalls in hygienic design 

The discussions and inputs by subject-matter experts clearly pointed out the stark limitations of legacy facility or equipment (b) when compared with the ideal choice of equipment that is hygienically designed. However, achieving the ideal is no mean task – for instance, 3-A takes a holistic approach to hygienic design by integrating: 

  1. Equipment design 
  2. Facility design
  3. Cleaning and sanitizing protocols
  4. Operational design and GMP procedures
  5. Quality and regulation focus 

In line with the recent development of new GFSI industry scopes (1), JI (for building constructors and equipment manufacturers) and JII (for building and equipment users), we should expect Certification Program Owners (i.e., developers of GFSI benchmarked standards such as BRC, SQF, and FSSC 22000) to include these hygienic design benchmarking requirements in their near-future program versions. However, besides just the capital assets such as building and equipment, hygienic design principles should also be considered for sanitation and material handling tools, since tools can also become vectors of contamination if improperly designed, constructed, or installed (2). 

Since 2015, Remco has offered Vikan’s line of Ultra-Safe Technology brushes and brooms. These hygienically designed tools are ideal for use in high-risk food processing areas, such as in a ready-to-eat facility. Each tool has a smooth surface, and most importantly, is free of significant contamination traps, making them easier to clean (3)Contact us to help you with the proper selection, installation, storage, care, and maintenance procedures for hygienically designed tools. To see our selection of tools meant specifically for hygiene-sensitive environments (including our squeegees, handles, and one-piece shovels), click here. 

Notes and References: 

(a) About 3-A Sanitation Standards Inc: As an independent organization, 3-A Sanitary Standards Inc. principally relies on the collaboration and consensus of regulatory sanitarians, equipment fabricators and food processors when developing voluntary standards and accepted practices for food processing systems. More information about 3-A SSI is available at: http://www.3-a.org/. 

(b) Legacy facility or equipment is usually a term given to outdated, obsolete, old, or over-used capital assets used at a site that were not originally constructed and installed with hygienic design principles in mind, hence they may create more maintenance and breakage problems in the medium- to long-run. 

(1) https://www.3-a.org/News-Events-Updates/News/ArtMID/122397/ArticleID/651/3-A-SSIEHEDG-Endorse-New-GFSI-Hygienic-Design-Benchmarking-Requirements 

(2) https://remcoproducts.com/how-to-keep-cleaning-tools-from-becoming-vectors-of-contamination/ 

(3) https://remcoproducts.com/ust-white-paper/ 




Conference for Food Protection Workshop Sheds a Light on the Industry 4.0 Sanitation Challenges and Developments

Remco is proud to have participated at the Conference for Food Protection Virtual Workshop themed “The Impact of New Food Technologies and New Foods on the Food Safety Professional” from April 13 – 15, 2021.

In spite of the current challenges posed by the pandemic to the food retail and foodservice sector in the U.S. as well as globally, the expert panelists and participants from the industry, regulatory, academia, consumer, and professional arena were determined to deliberate on food safety and sanitation challenges and solutions arising from emerging Industry 4.0 technologies.

Some key topics discussed were on the following:

  • 3-D Printed Foods: Part of the talk centered around the limitations in proper cleaning and sanitizing regimes of 3-D printer equipment for producing next-generation foods.
  • Edible Cannabis: Where the regulation is left to individual states, the lack of standardized testing and the variable GMPs may accentuate food safety and sanitation problems.
  • Lab-Grown Meats: When compared with conventional meats, the novel technology is getting embroiled in complex regulation, allergen, and religious issues.
  • Virtual Reality/AI: Discussions featured food safety training with SmartGlass, predictive decision-making using algorithmic programs, and automated equipment troubleshooting.
  • Aggregating Social Media Data for Decision Making: Talks focused on the use of social media platforms for tracking foodborne illness incidents and unsafe foods in the market.

Remco will also be participating in the upcoming Virtual Biennial Conference from August 15-21, 2021, where the issues mainly centered around the Food Safety Code will be discussed.


Disclaimer: Through this blog, Remco is simply providing some opinions about the workshop. More specific information may be achieved by referring to the workshop archive at: http://www.foodprotect.org/biennial-meetings/2020-biennial-meeting/workshop/

Conference for Food Protection (CFP) is a non-profit organization that was established in 1971 to provide a formal process whereby members of industry, regulatory, academia, consumer, and professional groups are afforded equal input in the development or modification of food safety guidance, such as the U.S. Food Code. More information at: http://www.foodprotect.org/.

Industry 4.0: Generally refers to the Fourth Industrial Revolution or the “ongoing automation of traditional manufacturing and industry practices, using modern smart technologies.”

Understanding SQF Edition 9 Changes from a Hygiene & Sanitation Perspective

Safe Quality Food (SQF) is a GFSI-benchmarked food safety and quality management system standard. As a globally recognized certification program that covers the food supply chain (from primary production to foodservice), it is a popular standard with at least 80% of SQF-certified global sites located in U.S. and Canada.

According to SQFI, SQF Edition 9 Code audits will begin on May 24, 2021. Prepare for these changes by reading the major sanitation-related updates from SQF Edition 8.1 to Edition 9, listed below:

1. SQF Edition 9 food safety code books have become more sector-specific:

Previous Edition 8.1 Codes

NEW SQF Edition 9 Codes

GMP Modules Covered


  Primary Production

 Primary Plant Production

 Primary Animal Production

Aquaculture (Seafood Production)

7, 8, 10, 18






(Processed) Food Manufacturing

Pet Food Manufacturing

Animal Feed Manufacturing

Animal Product Manufacturing

Dietary Supplements Manufacturing






Food Packaging

Manufacture of Food Packaging


 Storage & Distribution

Storage & Distribution


Food Retail

N/A (Still Under Edition 8.1)


Food Service

N/A (Still Under Edition 8.1)


  • By referring to relevant code books, a site should be better able to address specific food safety aspects such as hygiene and sanitation GMPs, and other programs specific to their industry sector(s).

Note: In the subsequent points, we’ll focus on key changes in SQF Edition 9 Code: Food Manufacturing.

2. There is a significant transformation of GMP module sections and elements. As a key example of this, some of the following Module 11 (GMP for Processed Foods) sections have been reorganized and/or updated:

 11.1 Site location & premises


11.1.1 Premise location and approval

11.1.2 Building materials

11.1.3 Lighting and light fittings

11.1.4 Inspection/quality control area

11.1.5 Dust, insect, and pest proofing

11.1.6 Ventilation

11.1.7 Equipment and utensils

11.1.8 Grounds and roadways

11.2 Site operation


11.2.1 Repairs and maintenance

11.2.2 Maintenance staff and contractors

11.2.3 Calibration

11.2.4 Pest prevention

11.2.5 Cleaning and sanitation


11.3 Personnel hygiene & welfare


11.3.1 Personnel welfare

11.3.2 Handwashing

11.3.3 Clothing and personal effects

11.3.4 Visitors

11.3.5 Staff amenities (change rooms, toilets, break rooms)

  • These changes have promoted more structural clarity in sanitation and related GMPs, and further reduced redundancies within the codes.

3. There’s an enhanced focus on cross-contamination prevention. Module element further states that: “… Unprocessed raw materials shall be received and stored separately from processed raw materials to avoid cross-contamination risk.

  • We’ve been saying consistently over the years that color-coding is a preventive control strategy that can work to significantly reduce contamination incidents within food facilities, whether we are designating distinct hygienic zones or separating color-coded tools in raw and ready-to-eat zones (RTE) to help avoid cross-contamination, or allocating identifiable cleaning tools for food-contact surfaces and non-food contact surfaces.

4. Module element on air testing requirements for high-risk processes states: “Ambient-air [in such areas] shall be tested at least annually to confirm that it does not pose a risk to food safety.

  • This requirement points to the need for maintaining air hygiene in high-risk zones such as RTE prep rooms or exposed product handling areas. Microbes or allergens may aerosolize and contaminate food and other surfaces. One way of controlling these hazards is through the right choice of mechanical tools and methods to ensure effective cleaning while preventing/minimizing contamination spread over time.

5. Foreign matter contamination control has become more relevant. Module element further requires that inspections must be performed to ensure “… plant and equipment remain in good condition, and [that] equipment has not become detached or deteriorated, and is free from potential contaminants.

  • Sanitation requires buildings and equipment be cleaned based on risk assessments and that only durable tools that can withstand operating conditions (i.e., varied temperature, chemical use, and mechanical stresses) over time are used. A common query we get is: Do metal detectable bristled brushes really work in reducing foreign matter contamination? A reliable technical study has shown that such kind of bristles do more harm than good since they tend to be more brittle and difficult to detect due to their size. A better solution would be color-coded, hygienically designed brushes with the right type of bristles secured onto the block.

6. Greater accountability of non-conforming site and equipment is now required. System element on internal audits and inspections states: “Regular inspections of the site and equipment shall be planned and carried out to verify GMP and facility and equipment maintenance are compliant to the Code requirements. The site shall also take corrections or corrective and preventive action, and maintain records of inspections and [on] any corrective action taken.”

  • Tools, as material handling or cleaning equipment, have the potential to easily become vectors of key contaminants, e.g., microbial biofilms, allergens, and foreign matter, and therefore, a contaminated tool should be treated like a non-conforming environmental surface that’s capable of creating a food safety hazard. Hence, cleaning tool maintenance becomes absolutely critical, and these implemented preventative actions should also be accounted for.

7. There’s a widened focus on the review of specifications critical to food safety. System element requires that: “Specifications for raw materials and packaging, chemicals, processing aids, contract services, and finished products shall be reviewed as changes occur that impact product safety… A list of all the above specifications shall be maintained and kept current.”

  • Tool specifications, in our view, can also impact food safety. Tools and utensils used in food processing operations must be compliant with 21 CFR FDA or equivalent regulatory requirements. Remco offers a range of FDA-complaint cleaning and material handling tools to our clients. Our FDA-compliant tools all have up-to-date technical specifications, declarations of compliance, guidance, and technical support, where required.

8. Expansion of hygienic design requirements for sites and equipment should be expected. With the alignment of SQF Edition 9 Codes to the new GFSI Benchmarking Document 2020, hygienic design industry scopes (i.e., JI and JII) should prominently feature in the near-future-standards. Moreover, benefits of ease in accessibility, inspection, cleaning, and maintenance of newly designed and installed sites and equipment shall eventually be realized by stakeholders through proper adoption of these scopes.

9. Food Safety Culture is a new component in the Edition 9 Codes. System element on management responsibility states that “senior site management shall lead and support a food safety culture within the site…” Food safety culture is defined as a set of food safety-related attitudes, values, and beliefs that are shared by a group of organization members.

  • Remco’s sales and support team can help by offering cleaning and material handling tools that meet the site’s food safety objectives by offering and recommending viable color-coding solutions in tool selection, usage, cleaning, storage, care, and maintenance requirements, which has been shown to strengthen food safety culture in an organization. To schedule a complimentary site visit with one of our trained and experienced business development managers who understand the SQF Codes and other food safety requirements, click here.

Please note: The author has sampled just the significant changes in SQF Edition 9 Food Safety Code for Food Manufacturing (assuming a transition from previous Edition 8.1 to new Edition) that support our company’s relevant viewpoints and best possible industry advice on key sanitation and hygiene requirements. Refer to the SQFI website as the best resource for comprehensive information on understanding and preparing for the SQF Edition 9 Code certification standard requirements for a site. For any queries on the advisory information above, feel free to email us at edtech@remcoproducts.com.



How to manage allergens in confectionery production

This article, written by Remco’s own Amit Kheradia, first appeared in Candy Industry on June 16, 2017. It has been updated for 2021.

For customers with food allergies, the simple pleasure of consuming a confection could have disastrous effects. Individuals with food allergies can rapidly develop symptoms of fever, vomiting, asthma, skin rashes, and hives, or they may even enter mild-to-severe anaphylactic shock. Compounding the problems of allergic reactions for consumers, there is a good chance they are allergic to more than one confectionery ingredient. The best way for consumers to prevent a reaction is to avoid products with declared allergens. However, consumers have no control over undeclared allergens, and that’s why manufacturers must recognize and separate common allergens in confectionery production.

According to Food Allergy Research and Education, up to 15 million Americans have food allergies, and the economic cost of children’s food allergies in the United States is about $25 billion each year. Undeclared allergens are also one of the most common reasons for food recalls. In 2014, undeclared allergens were behind half of the FDA’s fourth-quarter recalls. Moreover, according to the 2009-2012 FDA Reportable Foods Registry, about 90 percent of all reports involved three hazards: Salmonella, Listeria monocytogenes, and undeclared allergens, with undeclared allergens accounting for essentially the same number of reports as Salmonella (34 percent and 36 percent respectively).

An allergen is a type of antigen that, in specific individuals, produces an abnormally vigorous body response in which the immune system fights off a perceived threat that would otherwise be harmless to another person. These body responses are called allergies. Any protein-based product has the capability to elicit allergic reactions in humans at varying levels of severity. However, the following eight foods account for 90 percent of all food allergies: milk, eggs, peanuts, tree nuts, wheat, soy, fish, and shellfish.

So, how can we manage allergens in the confectionery industry?

Above all, the personnel preparing and handling confectionery products must be trained on allergen awareness and shown through proper demonstration how to prevent allergen cross-contact. This training should include identifying the various allergens in a facility, zones of production, material handling procedures, and appropriate sanitation practices.

The first line of defense starts with receiving raw ingredients. It is important to identify and separate different allergen-based products from each other, and from other non-allergen-based ingredients to avoid cross-contact. One helpful practice, for example, may be using white color-coded tags to identify milk-based ingredients, and green color-coded tags to denote peanut ingredients. This aids in tracking ingredients and helps avoid accidental mix-ups. The same concept could apply during storage and handling, as well as during other operational processes.

In storage areas, especially if allergen cross-contact is a significant hazard, additional precautions should be taken. One sample recommendation is storing wheat flour bags and soy flour bags side-by-side rather than one on top of the other. This reduces the chance of accidental cross-contact. During handling, care should also be taken not to pierce ingredient bags, as cross-contact between different ingredients may occur.

Material accountability through proper recordkeeping is another important part of training. For instance, if an operator is supposed to use 250 lbs. of milk powder in making a certain batch of product, and eventually ended up using 275 lbs., he/she must account for where the additional 25 lbs. was used. Was it wasted, spilled, or used in another product? Good recordkeeping subsequently strengthens the traceability and recall program for the facility.

Beyond training for allergen identification and material handling, training workers on sanitation practices reduces risks in the facility. When cleaning in high-risk areas, using hygienically designed tools helps mitigate the risk of cross-contact or cross-contamination. Specific color-coded sanitation tools can also be used in the presence of different allergens to further reduce risk. To verify the effectiveness of sanitation, a mere visual check may not be sufficient, and ATP swabs or specialized allergen swabs should be used. As an example, there are fast and reliable peanut detection kits that provide accurate and rapid results within minutes, and similar test kits are available for other common allergens.

A qualified and competent group of personnel should supervise employees to ensure that the allergen management program is effective. Oversight is one way is to confirm that employees are washing their hands and changing their protective equipment when moving from one allergen processing zone to another. Visual cues such as color-coded hairnets, gowns, smocks, aprons, or gloves may also assist in proper identification and segregation of employees working in a facility.

Apart from proper identification of the unique allergens and separation of ingredients, the key operation to focus on is processing. Production runs should be scheduled so that products with no allergens are processed first, followed by the product with least number of allergens, then second most, and so on (i.e., milk and wheat, followed by milk and wheat and soy products). After processing products with allergens, there must be a rigorous sanitation run before switching over to products with fewer, different, or no allergens. For instance, if you process a peanut-based confection and want to switch to a non-peanut-based confection, you must first clean and sanitize the food contact surfaces (equipment surfaces, conveyors, etc.). Then, you should sufficiently clean surrounding areas until no trace of the allergen is left.

Some allergen hazards extend beyond the production environment and should be considered by manufacturers. One potential hazard to consumers is that many do not know the scientific names listed on food labels. Because of this, product labels must explicitly list every allergen in the product. As an example, some products contain sodium caseinate, and many consumers are unaware that it is a milk-based ingredient. Therefore, apart from providing the scientific name, the label should explicitly state that the product contains milk. In addition, certain flavorings, spices, condiments, and preservatives may contain hidden allergens – for instance, tasty Cajun sauce might contain peanuts.

Another important point to note is that certain countries may recognize a wider array of allergens than those recognized in the United States. For example, Canada recognizes mustard and sesame seeds as allergens. These international differences are especially important to consider when importing or exporting products.

With the projected global confectionery market projected to reach $275.8 billion by 2025, the cost of recalls due to allergens will be an ever-increasing issue. Manufacturers can reduce the risk of these costly incidents by instituting a preventive allergen management program that runs across their production facilities and training the workforce on that program.

Celebrating FSMA’s 10th Anniversary: What have we achieved, and what’s to come in 2021?

blue workstation

Ten years ago, on January 4th, President Obama signed into law the Food Safety Modernization Act (FSMA). This act enables the FDA to better protect public health by focusing more on preventing food safety problems rather than simply reacting to them. Looking through a decade of U.S. regulatory challenges and achievements, so far, seven FSMA Final Rules and several guidelines have been published, and most food industries are already complying with the relevant requirements. Other FSMA compliance date deadlines to look out for are as follows:

FSMA Final Rule


Compliance Date Deadline

Produce Safety

Other Produce – Small Farms (remaining water requirements)

Jan. 26, 2021

Other Produce – Very Small Farms (remaining water requirements)

Jan. 26, 2022

Small Farms – Non-sprout agricultural water requirements

Jan. 26, 2023

Very Small Farms – Non-sprout agricultural water requirements

Jan. 26, 2024

Intentional Adulteration

Very Small Businesses

July 26, 2021


For more current information on FSMA compliance requirements, visit the FDA’s website.

The battle is still far from being won – allergen labeling and management remains the top cited cause for product recalls, and contamination by Listeria monocytogenes and Salmonella continue to be the leading causes of foodborne illness outbreaks. These trends indicate that regulatory agencies, industry stakeholders, and allied groups should continue to make a concerted effort in providing safe and wholesome food to consumers. In light of increased hospitalizations during the ongoing pandemic, controlling for allergens and contaminants are even more critical as we face an already strained healthcare system. 

This year should see significant activities centered around strengthening industry requirements toward FSMA compliance. The following are some of the recent developments to potentially keep track of:

  1. Collaboration and Integration within Agencies: Expect more open communication among North American regulatory agencies such as the FDA, FSIS, and the CFIA and stakeholders. One such collaborative initiative that has been spearheaded by these organizations is on Salmonella reduction efforts in meat, poultry, and produce to meet Healthy People 2030 global targets. 
  2. Digitization of Food Safety Processes and Systems: To meet increasing record-keeping requirements, industries will make a greater effort to move away from physical paperwork and towards digitization and the use of AI and Data analytics technologies. Companies should be able to take advantage of real-time, block-chain, or predictive capabilities to help in hazard prevention, but these systems must also meet the 21 CFR 11 requirements on electronic record-keeping.
  3. Preparing for a New Era of Smarter Food Safety: The FDA’s Blueprint was launched in July last year as the agency’s masterplan towards creating a more digital, traceable, safer, and FSMA-based food network system that should help bend the curve of foodborne illnesses in the U.S. We should expect more developments for this initiative in 2021.
  4. Traceability as a Preventive Approach: The ability to trace and track the source of foodborne illnesses to be able to better prevent future outbreaks has become one of the FDA’s priorities. This year we look forward to the finalization of FSMA’s proposed Rule for Food Traceability, which should mandate additional record-keeping requirements for certain high-risk foods.
  5. Enhanced Focus on Sanitation Controls: With sanitation being elevated to one of the hazard analysis risk-based preventive controls, there should be an increased industry focus toward an integrated sanitation approach. Such an approach should also include the selection, cleaning, storage, and maintenance of cleaning tools, as such equipment can also become vectors of contamination in a food plant.

For more updates on the FDA’s Viewpoint on FSMA progress and the path forward, visit the FDA’s website.


2020 Food Safety Development Recaps in Anticipation for 2021 and Beyond – The Future is Now!

With the COVID-19 pandemic raging on, it’s essential for the global food supply and food safety systems to keep delivering safe and quality food to consumers. Notably, the message from the FDA has been clear: “There is no evidence, as yet, regarding transmission of COVID-19 through food and food packaging.” 

However, out of an abundance of caution, we recommend that the industry and public-at-large keep abreast of relevant regulatory changes and follow science-based experts’ guidelines. Furthermore, as we all look forward to the progress on the vaccines, CDC/WHO/Public Health guidelines on minimizing the virus transmission and spread will still need to be followed.

This has definitely been a year of challenges for the food industry; however, let’s take a moment to recall some of the significant developments in food safety that should positively influence the North American food safety landscape in the years to come:

  • On July 13, the FDA unveiled its blueprint on the ‘New Era of Smarter Food Safety’ on creating a more digital, traceable and safer food network system to help reduce food illnesses in the U.S.
  • On August 22, the FSIS-USDA held a virtual public meeting to launch the “Roadmap to Reducing Salmonella” for meat, poultry, and egg products, and also to meet part of the Healthy People 2030 goals.
  • On November 18, the FDA released a new outbreak investigation tool that shall tabulate all foodborne outbreaks in an effort to initiate an early response from the FDA’s CORE (Coordinated Outbreak Response & Evaluation) team.

During the last quarter of this year, the FDA cited an inspectional violation to a manufacturing facility because of poor cleaning tool storage and use that led to RTE product cross-contamination. This reinforces the point we have been making for years that tools are vectors of contamination and so they need to be properly selected, used, cleaned, stored, and maintained.

Here is a list of key food safety-related developments to look out for in 2021:

  1. The FDA has just released the Proposed Rule for Food Traceability to provide the basis for additional traceability recordkeeping for certain foods based on Section 204 of FSMA. In 2021, we should expect a finalization of the rule and more guidelines, specifically on the Food Traceability List.
  2. SQF Edition 9 Code books were published during the latter half of 2020. In a nutshell, the new codes now reflect a more sector-specific approach, and with an emphasis on food safety culture. The new codes shall be aligned to the newest GFSI Benchmarking Documents Version 2020. SQF Edition 9 is expected to become the auditing standard from May 24, 2021 onward.
  3. GFSI version 2020 has also incorporated two new scopes of recognition on Hygienic Design i.e., JI and JII. We should expect more food safety system requirements regarding hygienically designed facilities, equipment, tools, and utensils in the very near future.

Important Company News:

  • In order to effectively serve grocery stores, our parent company, Vikan, has launched the Food Retail line of products and solutions. To download the guide, click here.
  • Remco now stocks high temperature resistant tools that can be effectively used for cleaning ovens or other heated surfaces. 
  • Our SQF practitioner-qualified, HACCP- and PCQI-certified Business Development Managers are now capable of conducting virtual site assessments. To request a site visit, contact us.

Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene and material handling equipment, appreciate and wholly support the role of the food industry and the front-line workers in assuring food safety and sanitation even during these trying times. 

We earnestly look forward to a healthy, prosperous, and stable 2021 for all. Meanwhile, we wish everyone happy holidays and a safe season!