another craft chocolate recall
there's nothing clearer than the need for consistent bean to bar food safety routines
In less than a year, two craft chocolate companies have had recalls due to allergen-contaminated chocolate bars: Dick Taylor, in September 2023, and now Chuao.
During a recall, the maker and the details of the recall are listed on the FDA (Food and Drug Administration) website.
In Dick Taylor’s recall, a chocolate containing peanuts was mislabled before being sold;
Dick Taylor Craft Chocolate of Eureka, California is recalling “Ginger Snap Milk Chocolate” batch 23194 because they were mis-packaged and are Peanut Butter Dark Chocolate bars in Ginger Snap wrappers and contain undeclared peanuts. People who have allergies to peanuts are at risk of serious life-threatening allergic reaction if they consume these products.
in the case of Chuao:
The recall was initiated after it was discovered hazelnuts were inadvertently added to the product during manufacturing and the lot produced was distributed in packaging that does not reveal the presence of hazelnuts. Subsequent investigation indicates the problem was caused by cross contamination on a piece of share equipment.
Every 10 seconds, food allergy sends a patient to the emergency room. Each year in the U.S., an estimated 3.4 million patients visit the emergency room because of their food allergy. Info from Foodallergy.org
From the U.S. Food and Drug Administration:
Food allergies are a significant public health concern with allergic reactions varying in severity from gastrointestinal disturbances and skin irritations, to anaphylaxis, anaphylactic shock and death. Consumers with allergies must avoid food with allergenic materials to prevent serious health consequences since there is no cure.
Lesson: if it can happen to even the most respected chocolate company, it can happen to any chocolate company.
I’m not going to address the potential brand harm, revenue loss, or hassle because those things are NOTHING in comparison to the loss of one single life, or the illness that might be caused, the trauma and grief. Anaphylaxis (airways swelling and being unabe to breathe) is a life or death situation.
On January 8, 2023, Kiki suffered a severe food allergy reaction. She used her Epi-pens and received emergency medical care but fell into a coma. She did not regain consciousness and died on January 13, 2023. She was twenty-five.
~~Tina Hedin, writer whose story was published in the New York Times
At a minimum:
Chocolate is a food, and every chocolate maker should take food safety seriously, and should take a food handler course; you can find them online.
Understand the nine leading causes of food allergies identified in the US are milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Gluten is an illness-causing allergen. Grains MUST be certified gluten-free if you plan to state on your label “gluten-free.” Example: oats are gf, but because they are often milled/processed on shared equipment, they are not gf unless certified gf.
Label every product correctly. In the U.S, we must adhere to the Food Allergen Labeling and Consumer Protection Act (FALCPA) If it’s added to the batch at any point it must be listed on the label.
When selling online, list the ingredients of a product in your product description and note any allergens used.
When working with allergens: create a prevention system and stick with it
Be aware of allergen ingredients in small spaces and take precautions to avoid cross-contamination.
Mark grinder bowls on all batches.
Keep a batch log of all batches.
Disassemble and wash grinder parts completely (stones, washers, etc) after an allergen-containing batch.
Wash moulds after tempering allergen-containing bars.
Understand how bar handling AFTER tempering/moulding can be managed to avoid potential issues.
During tempering and moulding, bars containing any common allergen should not share racks/trays with other bars, and should be placed for cooling on racks/trays clearly labeled with the allergen.
When the bars are unmoulded if (a) complete wrapping will not take place right away, the bars should be stored on labeled trays and covered, or, (b) if the bars are unmoulded and placed in an inner wrapper only, the bars should be stored in clearly labeled boxes or totes with lids.
Dick Tayor’s bars all pass down a depositing/moulding/cooling line then to an automatic bar sleeving machine. Once the bars are heat-sealed in the mylar inner wrapper they look identical to every bar they make. From this point the bars must be placed in clearly labeled containers BEFORE being sent to the wrapping room where the bars will be placed inside the outer wrapper.
For makers who use a single pouch-style wrapper, those wrappers should be labeled before the bars are placed inside.
If you temper~~cool~~unmould~~store for wrapping later: mark the storage trays
If you temper~~cool~~unmould~~place the bars inside an inner wrapper (foil, clear sleeve, glassine, parchment, mylar) that is used for every bar you produce, the bars should then be placed in a clearly labeled container before being moved.
If you temper~~cool~~unmould~~and immediately wrap, make sure to ONLY be wrapping allergen-containing bars at the wrapping table/station to avoid having the labels for other bars mistakenly used.
During unmoulding and wrapping, gloves should be worn. It is troubling seeing photos on social media of makers handling bars with bare hands; fingerprints aside, there is a potential for cross-contamination if a maker handles an allergen-containing bar and then picks up/touches a different bar. Allergic reactions can occur after trace amounts.
One way to minimize potential cross-contamination is to designate and clearly equipment that will be used with allergens; melangers, utensils, strainer, scoops, bowls, hotel/storage containers, cutting boards, etc, and anything that comes in contact with allergens used in bar production.
Eliminate the use of plastic storage containers for batches and use only stainless steel to avoid cross-contamination.
Make sure allergens aren’t airborne, or can enter other batches. Products like milk powder are light and “dusty,” and can travel.
Make sure your workspace is clean and organized.
As a rule wear gloves when handling allergen ingredients, when emptying/straining batches, and again when handling bars.
Wash and sanitize allergen-contaminated equipment, bowls, etc, separately from other equipment and bowls, etc.
If you have any good practices or insights you’ve put into place, I hope you’ll share them in the comments. Let’s help each other craft the best chocolate in the world, no matter the size of our melanger :)
In the UK we have to be able to trace one step forward and one step back for all ingredients in case of a recall. I have a log sheet where I record the batch number and source of every ingredient I use, then a batch control sheet where I log which ingredients go into each batch (and assign that batch a number which is marked on the packaging). My environmental health officer was really happy with it at my last inspection, so I'm happy to share it with anyone who would like it.
Also the UK food standards agency has free allergen awareness training on their website, I'd say even if you're not in the UK it's a handy resource