This book is the proceedings from a national conference on allergen management. Two leading research bodies, Leatherhead Food International (LFI), in conjunction with Campden BRI, hosted the conference to support the awareness and management of food allergens on the food industry. With food recalls due to cross contamination of allergens or incorrect allergen labelling an expensive problem for the food industry and dangerous for food-allergic consumers. Food Chain Allergen Management provides vital information on the tools available to enable businesses to manage allergens in the food chain. The book also includes information on allergen controls, the prevalence of food allergies, allergen management thresholds, auditing and retailer expectations. Essential reading for academics and industrialists in food science.
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Food recalls due to cross-contamination of allergens or incorrect allergen labelling are an expensive problem for the food industry, and dangerous for food-allergic consumers. It is crucial that the food industry understands how to manage allergens in the correct way; consumers are relying on the food industry to provide them with safe food suitable for what could be a potentially life-threatening allergy. Leatherhead Food Research is pleased to publish the proceedings of its highly successful Food Chain Allergen Management conference, held in May 2009. The event included presentations on the Standards available to enable businesses to manage allergens in the food chain, as well as examples of allergy recalls and contamination issues, a discussion on threshold levels for food allergens, and the view from Marks & Spencer, SainsburyÆs, Tesco and Waitrose on allergens and the systems that they use to deal with allergen issues. The publication also features an Introduction from David Highton of the British Standards Institute, and a Foreword by David Reading, Founder of the Anaphylaxis Campaign. An ideal supplement to any allergen-management programme. This book is an invaluable reference resource for all those involved in ingredients and process management, and HACCP implementation in the food industry.
CONTRIBUTORS, vii,
FOREWORD, xiii,
INTRODUCTION, xv,
1. DEVELOPMENT OF ALLERGEN MANAGEMENT THRESHOLDS, 1,
2. ALLERGEN MANAGEMENT - ACCIDENTAL TO ACRIMONIOUS: ALLERGY RECALLS AND CONTAMINATION ISSUES, 11,
3. ANAPHYLAXIS CAMPAIGN STANDARD, 23,
4. CONTROLLING AND COMMUNICATING, 33,
5. ALLERGENS: BUILDING THE FOUNDATIONS FOR A ROBUST PROGRAMME, 39,
6. STANDARDS, ESPECIALLY ALLERGEN CONTROL, AUDITS, INTERNAL INSPECTIONS AND THIRD PARTY, 47,
7. SUPPLY AND FACTORY CONTROL, 53,
8. I WANT IT ALL AND I WANT IT NOW! ALLERGY INFORMATION FOR CUSTOMERS, 59,
9. REGULATORY CONTROL, 65,
10. ALLERGEN CLEANING PROJECT, 71,
11. PATTERNS AND PREVELANCE OF FOOD ALLERGY ACROSS EUROPE, 75,
12. ALLERGENS - THE MOST VULNERABLE AREAS OF A FOOD FACTORY, 83,
INDEX, 89,
DEVELOPMENT OF ALLERGEN MANAGEMENT THRESHOLDS
Sue Hattersley
Head of Food Allergy Branch, Food Standards Agency
1.1 Introduction
This paper will cover a number of areas including what the Food Standards Agency has been doing in the area of allergen management, the consequences of poor allergen management, trying to draw some lessons from the incidents that have happened in the last 12 months, and what the Agency is planning to do in terms of taking forward the problem of how we determine the management threshold levels. Definition of allergen management thresholds is what the food industry is waiting for in order to be able to inform their advisory labelling decisions. Analytical methods will also be mentioned briefly.
So, as we all probably know, there is EU legislation that requires the labelling of a number of specified allergenic foods when they are used as deliberate ingredients in pre-packed foods. And this requirement, apart from sulphites, is for labelling of the deliberate ingredients, whatever the level of use, so that even the very minor ingredient at a very low level has to be labelled if it is deliberately added. However, the legislation doesn't cover the issue of allergen cross contamination, and so the situation could arise where there are higher levels of an allergen present as a result of cross contamination, which is not covered by the law and therefore may not be represented on the label of the food, whereas lower levels of an allergen which have been added deliberately as part of the product formulation do have to be labelled. In some countries the issue of cross contamination has been addressed, and if there is significant cross contamination with an allergen or allergens, then the allergens concerned can be included on the label as the last ingredient listing, but that is not permitted under EU Law. Ingredient labelling only includes an ingredient added deliberately as part of the product formulation, rather than if it is present as a cross contaminant.
1.2 Food Standards Agency Guidance Documents
The Food Standards Agency produced Best Practice Guidance on Allergen Management and Advisory Labelling in 2006 (1). This was produced once the legislation was in place covering the labelling of allergens as deliberate ingredients. The guidance was produced very much as a collaborative effort; the Food Standards Agency worked with a number of different stakeholders; the manufacturers, the retailers, the allergy support organisations, and also the enforcement bodies. This approach contributed to the success of the document because it covers a wide perspective, and is practical and helpful. The main Guidance document gives a decision tree approach to take people through allergen management. This publication is intended to help Trading Standards enforcement officers and the larger food businesses. A leaflet entitled 'Allergy – what to consider when labelling food' (2) was also produced for the smaller food businesses, which covered in outline form both the labelling requirements and the issue of allergen cross contamination. The guidance was disseminated through the stakeholders that were involved in drafting the document; so it went through the trade bodies to the industry, and through LACORS to the enforcement officers. In addition, the Agency has always provided training for enforcement officers, and so the guidance was promoted by that route to the enforcers because that was felt to be a good way to reach the smaller businesses.
This Guidance has been updated recently, because at the time it was produced, Lupin and Molluscs were not on the list of allergens that had to be labelled, and the update reflects these additions to the list of allergens for mandatory labelling.
The food industry asked the Food Standards Agency to help in the provision of clear guidance to be used across all food sectors, and this resulted in the production of these Guidance documents. The food industry was very aware of the risks from cross contamination with food allergens, and wanted to provide meaningful and helpful information to allergic consumers. At that time in 2005 there was no legislation or authoritative guidance on how to manage allergen cross contamination; the industry had different guidance documents, but there was nothing available in a cohesive form. Some guidance addressed one allergen, some addressed a few allergens. There was no consolidated picture. The food industry had no consistent approach to managing allergens, and no guidance when making decisions on when to put allergen advisory labelling on pack. Another issue relates to appropriate analytical methods for detecting and measuring the presence of allergens; if the presence of allergens in foods is going to be controlled, there need to be the analytical methods available to measure them. Analytical methods will be discussed at the end of this paper.
1.3 Warning Labelling
The Food Standards Agency was receiving a lot of information from consumers who were very confused by the advisory labelling that they were seeing on products. The different words and phrases that appear on different products were found to be confusing. Consumers also over-interpret the messages given; if labelling information is used that says there is a risk of cross contamination because nuts are also handled in the factory, the consumers will try to determine a level of risk that they think that phrase conveys. If consumers see a statement on pack that says 'made on the same production equipment', they also think that's a risk, and they will try and assign a level of risk to that. It's very clear that the labelling describes how the risk arises. However, the wording used doesn't really say anything to quantify the level of risk, but consumers judge the risk based on their own interpretation of the wording, and so they're making decisions based on the different phrases that are being used. There's also consumer concern that the labels covering the possible presence of allergens in foods are over-used, and obviously they restrict choice if consumers avoid all foods carrying warning labels. What we tend to see, particularly in teenagers, which is a group that the FSA have studied, is that they think the warning is used in order to protect the food business, and is not there to protect the consumer, and the warning is ignored because the impression is that the warnings don't...
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