Most in the UK food industry would probably consider overall food safety in the sector to be improving. In areas such as microbiology, foreign bodies and chemical contaminants, this appears to be the case. But when it comes to allergens, the Food Standards Agency’s (FSA’s) Annual Report of Incidents for 2015 shows a rise in alerts from 47 in 2013 to 60 last year.
By way of explanation, the report emphasises the possible impact of enforcement agency sampling priorities on the number of allergen-related incidents – and alerts. Last year, those priorities included undeclared sulphites in dried fruits and the absence of nut labelling.
In fact, at the International Life Sciences Institute (ILSI), chair of the European Food Allergy Taskforce René Crevel points out that there is no clear pattern or trend in FSA allergy alerts going back to 2008, when the number stood at the same level as the most recent figure. Indeed, the total for 2012 was appreciably higher.
Nonetheless, quality assurance software supplier Qadex calls the year-on-year increase in alerts “worrying”. And even if there is no evidence of a trend, the fact that the number of serious allergen-related incidents remains pretty stable rather than being reduced remains a concern.
Whatever the scale of risk, the British Retail Consortium (BRC) does not detect any significant change in the origins of that risk. As technical specialist for food at BRC Global Standards John Figgins puts it: “The threats have not changed recently. However, the food industry, allergen researchers and regulatory authorities continue to research this area, and understanding of the risks and therefore the good practice needed to manage the risks continues to grow.”
In the light of this improved understanding, the BRC amended its guidance around allergens in the latest issue of the Global Standard for Food Safety, which has been the basis of audits since the beginning of July.
Allergen labelling (Return to top)
“It includes a range of new requirements, including an increased focus on allergen labelling and packing controls,” says Figgins. “They were added as a response to the fact that these are some of the most common causes of the allergen alerts issued in many countries.”
Whyte adds: “Around half of allergen-based recalls are down to product being put into the wrong pack. The other half are to do with correctly-packed product carrying the wrong information on the label.”
Once again, there are two main causes for this mislabelling, he says: the manufacturer can make a mistake in recording product-related information; or the manufacturer may be given the wrong information in the first place
Regarding these sources of risk, the amended BRC standard's section 5.2 on Product Labelling states: ‘There shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications.’ Following this, the standard includes a substantial section dedicated specifically to management of allergens, looking at issues such as cross-contamination.
“When it comes to allocating the correct packaging to the line, it’s about making sure there's a formal control system in place,” says Figgins. Systematic record-keeping is also essential. But while the standard refers to correct set-up (including alerts) for online vision systems in a later section on labelling and pack control, the BRC emphasises that costly vision systems are not an expectation. “It’s about ensuring that the site has a process in place, with the flexibility to allow different types and sizes of company to carry out the task in different ways,” says Figgins.
However, Whyte says: “The biggest challenge that UK manufacturers are facing is a lack of allergen awareness through the supply chain.” This is particularly true of ingredients sourced from Asia, where allergies are not seen as a problem, he adds.
Another problem revolves around how allergens (and their associated risks) are measured and how the threshold for precautionary labelling is defined.
Threshold values (Return to top)
ILSI’s Crevel says: “Precautionary thresholds are useful in helping to create a level playing field and giving improved consumer protection. I think the European Commission (EC) understands the issues and is moving towards them.”
However, any movement on the part of the EC has, to date, appeared glacier-like. In fact, although Article 36 of the EU Food Information for Consumers Regulation (FIC), 2014, calls for a framework within which voluntary information must comply, no timetable has been set for drawing this up with relation to allergen levels.
Crevel, who is also science leader for allergy and immunology at Unilever, has made predictions in the past about a timescale for the EU’s introduction of thresholds. But now he says that recent alerts could serve to underline the need for action in this area.
Meanwhile, the ILSI Taskforce has been working towards an international consensus on how to assess the risks associated with allergens. It is also working on tools to help manage that risk.
One complication, which could be delaying progress, is the current ‘voluntary’ status of allergen information in the EU. Many would like to see this information made mandatory, says Crevel. He traces at least part of the thinking behind mandatory analysis and labelling back to the Australasian Voluntary Incidental Trace Allergen Labelling (VITAL) initiative.
“It was pointed out that, if a certain food carries no Precautionary Allergen Label (PAL), the consumer needs to know whether it has been through a risk assessment or not,” he recalls. “One can see the logic behind that.”
In other words, the absence of a PAL may currently indicate either a lack of potential allergens or just a lack of any testing.
Paradoxically, any move to make this information mandatory could slow down EU regulatory implementation still further, given that the provisions of the FIC would need to be amended.
According to Crevel, the introduction of threshold values is keenly anticipated by industry. “Whether or not a product carries a PAL is currently dependent on an individual risk assessor’s perception of and aversion to risk,” he stresses.
The BRC agrees that threshold values would promote consistent approaches to assessment and labelling. But assistant director for food policy Andrea Martinez-Inchausti points out: “It would not solve all of the challenges associated with allergen management and, for example, would be unlikely to solve the challenges associated with particulate allergens such as nuts, where the allergen is unlikely to be distributed through the foodstuff, but could be present as a small piece.”
She adds: “There is also a concern in some areas that the use of threshold values could encourage a greater use of precautionary labelling, where current risk assessment methods suggest that such labelling is not required.”
In fact, one of ILSI’s objectives is to reduce the amount of precautionary labelling used. Crevel admits that combining this with the introduction of new benchmarking could be difficult to achieve. But he reports that all of the food manufacturers represented on the Taskforce want to see both PAL minimisation and the “level playing field” of threshold values.
Hazel Gowland, who runs advice and training organisation Allergy Action, highlights the point made by the BRC’s Martinez-Inchausti about particulate allergens. “Trying to establish thresholds is only part of the story,” she says.
Severity of reactions (Return to top)
When she says this, she is also referring to the greater attention currently being paid to the severity of allergic reactions rather than simply the dose of allergen in the product. One of Gowland’s roles is to advise the Anaphylaxis Campaign. But as she points out, while severity is now better understood as a critical element in the debate, it is extremely difficult to map or to quantify.
The ILSI Taskforce is alive to this higher profile now being given to severity, and is working towards papers and a workshop on this topic in just over a year’s time.
But Crevel says: “The current modelling is just to do with numbers. We can’t factor in severity at this stage. But one of our tasks will be how this can be integrated and used to help with risk assessment in future.”
Don’t miss Food Manufacture Group’s Food safety conference: ‘Safer food and drink – from harvest to home’, which takes place at The Lowry in Manchester on September 29 and includes a presentation on allergens. For more information visit the event website or call 01293 610354.