Allergen Recall Conundrum: Devising Corrective Behaviors That May Prevent Necessity of a Recall

May 25, 2017 11:15am

Tracey Phillips Beck
Vice President, Chief Counsel —Marketing, & Gov’t Affairs
Conagra Brands, Inc.

Maureen English Carroll
Associate General Counsel, Regulatory
Post Holdings, Inc.

  • Review of allergen requirements under FSMA and other applicable law
  • Devising methods to fill the knowledge gap which testing doesn’t always provide
    • Contamination from soy and dairy inside facilities and dealing with bad results
  • Using experts effectively for allergen identification and recall process
  • In-house counsel strategies for allergen recall
    • What is the reasonable timeline?
    • When should FDA be contacted?
  • Weighing the benefits between making “free of” claim vs. making no claim at all