By Michelle Berriedale-Johnson, Free From Matters
Michelle Berriedale-Johnson has been involved with food sensitivity for nearly 30 years and edits the FreeFrom Matters family of websites, a major online resource for food allergy, intolerance and sensitivity. Here, Michelle explains the importance of clearly labelling food products that may be consumed by people with allergies and intolerances.
Please note, these are Michelle’s personal views about the topic.
MAKING FOOD LABELLING EASIER TO UNDERSTAND
Allergen labelling today is a fraught topic. New regulations came into force at the end of last year (2014) and in theory were going to allow allergic consumers to identify their allergens more easily, and thereby avoid them. In Europe, food allergens are monitored and assessed by clinical and scientific experts through the European Food Safety Authority (EFSA). They advise on which foods need to be labelled on pre-packed foods.
In some respects the situation has greatly improved. As long as your allergy is one EFSA has defined as the ‘14 major allergens’ (which includes milk, eggs, nuts, shellfish and soya – see the full list at the bottom of this article), then it will be highlighted in the ingredients list and easy to see.
Unfortunately this regulatory change only covers what the industry refers to as ‘intentional inclusion’ – the ingredients that are actually meant to go into the product. The regulations have nothing, or at least nothing helpful, to say about accidental allergen contamination which is the chance that a product could accidentally become contaminated by an allergen, such as milk or peanuts, in the process of manufacture.
ACCIDENTIAL CONTAMINATION RISKS
It is only within the last five years, since allergen awareness has become so much more acute and transparency in food manufacture has been made a requirement, that accidental contamination has become an issue.
The assumption used to be that, if the product did not contain an allergen in the ingredients, then there was no risk to the allergic consumer. However, as manufacture and testing has become more sophisticated it has been realised that sufficiently large fragments of allergens can migrate around a factory and turn up in a product in which they were not intended to appear.
These fragments can include peanuts, sesame seeds, milk proteins or wheat flour, and can appear in a quantity large enough to cause a reaction in a sensitive consumer.
This has led to a tightening of risk assessment procedures and manufacturing processes and has also heightened awareness of the potential dangers to allergic consumers of allergen contamination. While this is an excellent thing, it has led to a certain degree of overkill in terms of warnings.
A ‘MAY CONTAIN’ WARNING – WHY IT EXISTS
The Food Standards Agency’s (FSA) advice to manufacturers is that if, after proper risk assessments have been done, there is no credible and demonstrable risk of allergen contamination, there is no need to add a ‘may contain’ warning on a product.
However, manufacturers nervous of the consequences of the unlikely event of a consumer suffering a reaction, are often using ‘may contain’ warnings even when the risk, by the FSA’s standards, is neither credible nor demonstrable.
The situation is compounded by the fact that precautionary ’may contain’ warnings are usually unspecific. This means that there is no way that the consumer can know whether there is a serious risk of contamination or whether the risk was really very tiny.
What this means for the consumer is that they either have to ‘play safe’ and avoid all products which carry a ‘may contain’ warning or they have to ignore the warning and take a risk, which could have serious consequences if the contamination level was quite high.
The safest route for both manufacturer and consumer is if the product is made in a dedicated free-from factory. However, these dedicated facilities are expensive and relatively rare and even then, the problem is not solved.
Partly as a result of recent ‘scandals’, such as ‘horse gate’ in 2013 (where traces of horsemeat were found in products intended for human consumption), traceability and transparency in the chain of supply have recently become all important in the food market.
In the ‘Free From’ world this means that not only must a manufacturer be sure that their own premises are allergen free, but they must be sure that none of their ingredients have been allergen contaminated before they actually arrived at their factory. Yet another reason for a manufacturer to add that precautionary warning.
EDUCATING THE PUBLIC – WHY WE SHOULD ALL BE VIGILANT AND CHECKING LABELS
This makes for a very unsatisfactory situation as far as the consumer is concerned. This becomes especially apparent when you consider that most of the deaths from food anaphylaxis occur as a result not of contamination, but of human error and mistakes, e.g. the person did not read the label or an allergen was included in the dish when it shouldn’t have been.
Some experts therefore believe that what we actually need to focus on is eliminating mistakes and educating consumers to read and understand labels rather than stressing over possible contamination issues.
Today, far from engaging with the problem, the new regulations have for now left it to industry to muddle along as best they can. As a result, innumerable apps have appeared attempting to guide the ‘Free From’ shopper up and down the ‘Free From’ aisles. Meanwhile some retailers are also making active efforts to guide shoppers round their own ‘Free From’ offering – the new Holland & Barrett More store and specialist ranges, being particularly pro-active in this area.
Holland & Barrett’s very extensive (and rather jolly) online ‘Free From’ store not only lists all of the products which would be allergen free (dairy, egg, nut etc.) but also gives you a filter system to show you which ones carry may contain warnings for other allergens.
This is very important if you are, for instance, a coeliac looking for a gluten-free bread but you also have a nut allergy. They have also included a couple ingredients which are not on the list of 14 allergens (such as kiwi fruit and sugar) but are none the less of concern to a number of allergy and intolerance sufferers. This is all very helpful to that confused ‘Free From’ shopper, so well done to Holland & Barrett and may others follow where you lead.
The 14 major allergens – as specified by the EFSA (European Food Safety Authority)
- Cereals containing gluten, namely: wheat (such as spelt and Khorasan wheat), rye, barley, oats
- Crustaceans for example prawns, crabs, lobster, crayfish
- Nuts; namely almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia (or Queensland) nuts
- Celery (including celeriac)
- Sulphur dioxide/sulphites, where added and at a level above 10mg/kg in the finished product. This can be used as a preservative in dried fruit
- Lupin which includes lupin seeds and flour and can be found in types of bread, pastries and pasta
- Molluscs like clams, mussels, whelks, oysters, snails and squid
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