Hi all,
Let me try to contribute to this indeed very interesting subject, by giving you an idea of how we managed things in the company where I work (importing foodstuff from the Asian countries.... full of allergenics!)
First of all I must say that European law and also the Greek law request that we must state all the ingredients of a product that could cause an allergy on the label, under the list of ingredients. In addition to that there can be an extra phrase stating "This product contains (this or that allergenic)". So this is what we do.
Also, we ask our providers to give us a production flow-chart for every product and a list of all the raw materials that they use (generally) and to inform us if there is any possibility for a cross-contamination. In addition, we occasionaly send samples for analysis (if we suspect that there is a "hidden" allergenic. So we add the phrase "this product may contain traces of nut.... egg...." and so on.
But what happens with unpacked and unlabelled products like bread for instance? Bread sold in Greece is most of the times covered by sesame - and bread is not packed nor labelled, yet I suppose that people with an allergy to sesame must know that they can't eat it. I mean that people with an allergy MUST know what they are allergic to and MUST read the labels. It's not your responsibility to teach people that they must read the labels in order to know what they eat.
Concerning the HACCP/ISO, we DON'T consider allergenics is a CCP (just a hazard) BUT we consider that correct labeling is. What we also did (and the auditors were very persistant on checking it during our ISO audit) was to include the allergenic precaution under the term "USE OF PRODUCT" in every product's data sheet (we call it product specification) and to include the "product specification sheet" into our list on encoded-controlled documents.
I hope everyone understands what I mean.
I would also like to add a comment concerning the labelling of tuna with a warning "this product contains fish". It may sound funny, but not everybody understands that tuna is a fish (especially if you live in a place with a lot of tourists), but everybody understands what a fish is. We import a product from the Philippines called "Dillis" and we have this warning because most of the Greek consumers are not obliged to know that dillis is a kind of fish.
Concerning the limits of intolerance... no one can really tell. It depends on the person's biology. I have heard of someone that DIED because he eat something that was fried in a pan where soybean oil was used previously and it was not washed carefuly.
Also, we had a talk with a friend trying for months to find out where the egg was coming from on some of their pasta products, since they have two separate production lines in two separate rooms....(one for the products with egg and another for the ones without egg)... well, they found out that there was some egg powder remaining on the sleeves of some of the workers who were passing from the one room to the other... And they ended up by separating the workers as well!
Greetings everyone!
Kelly