SYNLAB Laboratories’ Dr Mike Bromley lifts the lid on the laws surrounding testing and labelling allergens and the biggest risks along the supply chain.
Recent estimates suggest that between one and five percent of the world’s population have a clinically proven food allergy, with around two million people in the UK thought to be affected. For those affected by a food allergy, quality of life can be affected through the direct exposure to an allergen or even indirectly through a consistent fear of being exposed. This fear is not unwarranted as the most recent reports suggest in the UK alone five to ten people die each year because of food allergen exposure.
To date, allergens have been found to be present in a wide and diverse range of foods. The presence of these allergens in our food is considered a significant health risk and regulation, including the Food Information for Consumers (FIC), has specified that certain allergens must be declared if they appear as an ingredient in any food including nuts, milk, fish and any cereals containing gluten. The regulation applies to food business operators at all stages of the food chain and covers both packaged and unpackaged foodstuffs, including any food sold in retail or catering establishments. This places an emphasis on any food manufacturer, supplier or retailer to ensure allergen information is available throughout the chain in order to protect consumers.
Most allergen-based recalls are down to one of two errors: either a product has been placed in the wrong packaging or a correctly-packed product has incorrect or inaccurate information on its label. The two main causes for mislabelling are mistakes in recording product-related information or manufacturers being given the wrong information in the first place. Changes to section 5.2 Product Labelling in 2015 include specific requirements around how evidence must be provided and state that ‘there shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications.’ This means that it’s essential for companies to have a formal procedure in place in order to ensure they are compliant with the latest rulings. The legislation also includes a substantial subsection with a focus on allergy management and the issue of cross-contamination. It’s therefore evident that the allergens must be addressed by suppliers, manufacturers, caterers and retailers alike as each could be held accountable for misleading packaging or inadvertent food fraud.
There is certainly confusion and a lack of knowledge with regards to testing methods and labelling requirements in the UK. For starters, there are misunderstandings around the difference between validation and verification; verification is the process of ensuring the correct monitoring procedures take place whereas validation is the process of ensuring set limits control the hazard. What’s more, there can be confusion around the requirements surrounding allergen risk-assessment as well as the meaning of ‘may contain’ labelling. Further to this, stating that allergens are not present as ingredients is not the same as declaring a product is completely free from a particular allergen. This is due to the fact that any claim of a product is entirely ‘free from’ a particular allergen must be based on specific and rigorous controls including assurance that anything that has come into contact with the product – including packing materials – has not been in contact with that particular allergen. Details like this should be made overtly clear to customers to avoid confusion, however, this raises the question as to how this is communicated including the spectre of the ‘may contain…’ declaration.
One particular section of the Food Information for Consumers (FIC) legislation makes indirect reference to this, stating that information provided on a voluntary basis ‘shall not mislead the customer’, ‘shall not be ambiguous’ and ‘shall be based on the relevant scientific data’. Some would argue that a blanket declaration that any allergen may be present could be misleading, and not based on available scientific (testing) data. Several companies have instead opted for a more informative approach stating that certain allergens are not used as ingredients in a specific product however the allergen is used on site or by their ingredient manufacturers.
Furthermore, some of the details of the rules surrounding allergens can often fly under the radar, for example, the definition of ‘free-from’ in some instances is vague. Most allergens do not have a legislated safe limit as insufficient scientific data is available to establish safe thresholds. Consensus has been derived in relation to gluten allergen. To label something as free-from gluten a food sample should contain no more than 20 parts per million (ppm) of gluten when tested. The matter of establishing safe thresholds for other allergens is a continuing issue, particularly because what might be deemed safe for one allergy sufferer may not be safe for another. This means that the thresholds that will eventually be identified as being ‘safe’ for the vast majority of the population probably will not be applicable to everyone. While research is ongoing the issue currently has no straightforward answer and for those working in the food industry this is yet another reason to seek advice from third-party experts before making free from declarations.
For companies that do make a move to extend their declarations to free-from, the financial rewards could potentially be very lucrative indeed. The free from food market has grown by an estimated 325% over the last 9 years to 2015 and is expected to exceed half a billion GBP sales in 2016 (Mintel). Leading UK retailers are leading the way in this field with Tesco and Asda recently heavily investing in the revamp of their own-brand free-from range. This is further evidence to suggest that it’s time for the food industry as a whole to respond to the growing market and cater for people with allergies and intolerances. However, there are many prominent risk areas along the food chain including manufacturer contamination, staff-introduced contaminants, cross-contamination and gaps in staff training or knowledge.
The risks in hospitality and the food service industries in particular are heightened due to frequent changes in food type being prepared, minimal space for storage and the pressures of immediate service to consumers. While these risks can generally be reduced or overcome with internal risk analysis, supplier checks, auditing and staff training, it is essential that the effectiveness of these measures be continually monitored at every stage of the chain. After all, even the most experienced and diligent of companies can fall foul of complacency – not forgetting that caterers and retailers have the added pressure of being consistently customer-facing and on the ‘front line’ of the food industry’s supply chain. It’s therefore essential for businesses to be extremely vigilant and ensure they have best-practice procedures in place and it remains vitally important that the science behind allergen labelling is sound. Implementing effective allergen risk assessment procedures would have massive benefits for a range of businesses in the food industry and in order to protect their company reputation, hospitality and catering providers could well begin to have stricter expectations of their suppliers and demand more rigorous testing methods be applied when it comes to allergen detection.
Unless companies employ on-site dedicated technical staff teams to make sure each allergen-detection procedure is followed rigorously, it’s inevitable that outside resources in the form of third-party support may need to be called upon in order to ensure compliancy and to safeguard the business as a whole. The sheer level of scientific knowledge and understanding required to ensure companies remain compliant with current legislation means that even the largest of firms will probably require some level of external support when it comes to testing for allergens and monitoring internal compliance procedures.
While it can be tempting to make investments into expensive software that generates really impressive visual outputs, the reality is that it’s more important for manufacturers to use the most reliable testing methods available to them – and thankfully the technology to support this does exist and doesn’t have to break the bank, even for smaller firms. For smaller businesses on an even tighter budget, advances in technology have resulted in affordable and accessible allergen testing methods and products entering the market. The emergence of these new technologies mean that companies of all sizes should be able to minimise the risks that they may not have thought of previously, ensuring they are demonstrating awareness and care around allergen issues such as cross-contamination.
Dr Mike Bromley was the founder of Genon Laboratories, now part of SYNLAB, and he is a lecturer in Medical Mycology at the University of Manchester..
SYNLAB, through the acquisition of Genon, are experts in food authenticity testing and developed ‘Test in a Box’ – an allergen testing kit specifically designed to be used on site for the catering and hospitality industries.