35 replies to this topic

[Charles Chew]

Is an allergen (potential or existing) a food safety element and if so, should it be classified as a "hazard" or merely an issue to be taken care of under "good label management"

There are also many situations of unforseen circumstances (such as traces of cross contaminations) that may promote potential risks to consumers particularly children.

However, if all producers were to play it safe by inserting "Warning: There could be traces of nuts in product" - then what purchasing options do the sensitive consumers have?

But one thing is for sure. Classifying allergens as CCPs is no joke and certainly an extremely mean task. What are your views to this issue?

See this web page - http://news.bbc.co.u...ire/4667434.stm

[bibi]

Is an allergen (potential or existing) a food safety element and if so, should it be classified as a "hazard" or merely an issue to be taken care of under "good label management"

There are also many situations of unforseen circumstances (such as traces of cross contaminations) that may promote potential risks to consumers particularly children.

However, if all producers were to play it safe by inserting "Warning: There could be traces of nuts in product" - then what purchasing options do the sensitive consumers have?

But one thing is for sure. Classifying allergens as CCPs is no joke and certainly an extremely mean task. What are your views to this issue?

See this web page - http://news.bbc.co.u...ire/4667434.stm

A sad event:
I am actually reviewing our HACCP system, I still wondering to put allergen as ccp or control measure in "good llabel management" as you said with a segregation and cleaning process
( we use wheat & sesame pulp seeds).
But what about consumer reading the label, do they really read a label?
Actually we often receive complaint for one product saying it 's burnt, as we put in our label just below the use by date "this product has a smoke flavour".

Thanks Charles to highliting the topic again, any other commemts.

BIBI

[Simon]

But what about consumer reading the label, do they really read a label?

That's no reason for not putting it on; it's called covering your Ass.

[Charles Chew]

Hi Bibi,

Although its indeed a sad event, but as Simon said, its a mean world and we need to cover our ass. Consumers know about themselves than we do and if they should be sensitive to any particular substances they would certainly be on the lookout on the label for information........have no fear of that.

And, with regards to "this product has a smoke flavor (burnt look)" - probably a good idea to indicate that Attention: "product has a smoke flavor with intentional burnt look"

[yorkshire]

Charles,

In the EU the deliberate inclusion of allergens is now covered by labelling laws but the accidental inclusion is not. This is where we get the "may contain" get out clause.

We have started included allergens in our HACCP study as we use both wheat flour and milk powder on site. The difficulty we found with it is on the critical limits, e.g. at what point do you say wheat gluten is harmful to the consumer; for this one we chose the Codex limits for gluten free (200ppm I think), but was this right? Should we even consider gluten? We are really at the stage of looking at the bigger risks of contamination, e.g. the possibilities someone used a bag of flour instead of another dry ingredient, then working our way down to smaller risks.

For the process flow we looked at wheat flour movements and areas where there could be an impact.

With nuts it is probably much harder as the reactions can be fatal. I don't know at what level severe reactions can occur, does anyone?

[Franco]

I don't know at what level severe reactions can occur, does anyone?

I'm afraid no one knows the answer Yorky.
Up to the best of my knowledge, a theshold limit has been established for gluten only.

[JaneOwen]

These guidance notes (which I believe are still in draft format) might clarify some of these issues:
http://www.food.gov....lguidance05.pdf

It aims to deal with assessing the risks of cross-contamination with allergens and then decide whether advisory labelling is appropriate - the idea being that the increasing proliferation of warnings to 'cover one's arse' is not particularly helpful to allergic consumers trying to find something they can actually eat...!

The guidance also gives some useful information on the prevalence and severity of reactions to the main allergen groups and also in some cases the level that can trigger a reaction.

Franco is right - the only level that has been set so far is for gluten (the codex Alimentarius Standard for gluten free products specifies a maximum of 200ppm).

[jamesgibb]

Charles,

ISO22000 has an allegen included in the definition of a hazard so as these definitions are internationally accepted I would always consider an allergen as a hazard

As Simon has said it is often just a "cover your backside" approach

Regarding nuts the reaction threshold level varies from person to person, a high risk persons reaction time reduces each time they come into contact with nuts - very scary when it happens to your flatmate and you have to inject them with adrenaline . His reaction was from smoking a "cigarette" that someone who had eaten peanuts had smoked before so the level of allergen was pretty low.

My Flatmate could have an allergic reaction just from being in the same room as someone who is eacting nuts apparently it was the small particles in their breath.

As I have said nut allergies are very scary (and a lawsuit waiting to happen).

Allergies are typically a western issue, apparently 1/1000 Americans actually have an allergy but 1/3 think they have. so having allergen free products increases your US market by 50%.

FYI - I recently bought a Tuna steak from a UK supermarket to find it was labelled "warning this product contains fish"

It does make you think we've gone a bit over the top in the EU

James

[Simon]

Charles,
Regarding nuts the reaction threshold level varies from person to person, a high risk persons reaction time reduces each time they come into contact with nuts - very scary when it happens to your flatmate and you have to inject them with adrenaline . His reaction was from smoking a "cigarette" that someone who had eaten peanuts had smoked before so the level of allergen was pretty low.

My Flatmate could have an allergic reaction just from being in the same room as someone who is eacting nuts apparently it was the small particles in their breath.

Wow! It must terrible to live like that.

FYI - I recently bought a Tuna steak from a UK supermarket to find it was labelled "warning this product contains fish"

LOL.

Regards,
Simon

[just me]

To my opinion, as a person who appreciates labels very much, noting the allergen is not wholly "covering the ass". I think people who are normal would take the label for granted.

I'm intolerent towards gluten, therefore I find the food products from UK particularly helpful as the warning signs are all there. Unfortunately because UK products are certainly not competative in terms of pricing, the only few places that I can get these limited products are in Tesco and Marks & Spencer.
BRC is really doing a wonderful job to protect the consumers.

Even the US products couldn't match...

Cheers,

[Simon]

To my opinion, as a person who appreciates labels very much, noting the allergen is not wholly "covering the ass".

Of course it depends on the size of the label and the size of the a...

[just me]

Aye.

But I wouldn't care of the size of either, as long as it is there...

Imagine there is modified starch as ingredient, but they fail to mention whether it is wheat starch or corn starch...
Some would even miss out the ingredients that was dosed in minute amount.

[Simon]

Aye.
But I wouldn't care of the size of either, as long as it is there...

Imagine there is modified starch as ingredient, but they fail to mention whether it is wheat starch or corn starch...
Some would even miss out the ingredients that was dosed in minute amount.

Yes apologies for being flippant on a serious subject JM. It's interesting to hear your comments on the quality of UK labelling V's other regions. Probably more the Food Standards Agency rather than the BRC though.

Regards,

Simon

[Hongyun]

Will this help?

http://www.saferpak....?showtopic=4333

Attached Files

•  Allergen_Management_Guide.pdf   672.19KB   66 downloads

[just me]

Yes apologies for being flippant on a serious subject JM. It's interesting to hear your comments on the quality of UK labelling V's other regions. Probably more the Food Standards Agency rather than the BRC though.

Regards,

Simon

It's good to know it is FSA. Thanks.
Yeah, apologies foe being over zealous on this subject. Most ppl who are not having these problems take it for granted, as I was before being diagnosed.

Cheers,

[Charles.C]

Dear All,

Since this topic is now a major item in the food safety world I would like to extend this thread slightly.

Although there seems to be a consensus that “allergen” is a hazard, there seems to be some debate as to whether labelling can be considered as a CCP or not.
(added - my apologies, should have also stated I was considering an intrinsically allergenic item to make the example easier)

I suspect it will come down to interpretation again but – the No case seems to be based on the clearly correct fact that no change in the allergenic characteristics of the product has occurred. On the other hand, I thought that the intention of HACCP was to reduce, eliminate etc the RISK of the hazard to an acceptable level for the consumer which it seems to me that labelling “may” be considered to have achieved (depending on yr viewpoint) so that a CCP could be a reasonable conclusion.

Any opinions ? (2C or not 2C - that is the question )

Rgds / Charles.C

[Simon]

Although there seems to be a consensus that “allergen” is a hazard, there seems to be some debate as to whether labelling can be considered as a CCP or not.

I think it is in the Packaging HACCP Plan you posted a link to on this thread.

[hSusan]

Will this help?

http://www.saferpak....?showtopic=4333

The attachment (not the link above) was quite detailed/useful - thanks for that Hongyun. Australia has a version too which is currently undergoing review so I'll not attach it here yet.

However it was interesting to note that most information focusses on cross contamination risk and has little to say about other issues that have actually triggered recalls in the past. For example I know of recalls (and other near misses that I've heard of) triggered by
packaging changeover issues - originating from the packaging supplier as well as at the food manufacturer's packaging line.

In the past I've also been told by a company of an issue that occurred due to an ingredient supply change that wasn't notified to the downline manufacturer - while this isn't something that can be managed by a ccp, it'd be very few HACCP plans that would consider how suppliers (or other external inputs) can contribute to an allergen hazard and this is probably the more important point.

Any thoughts on other non-cross contamination hazards that have come up in practice?

Susan

[Charles.C]

Dear Simon,

Thanks. I agree. Seemed to me this might be categorised as the Packaging Manufacturer voting a support YES to a Food Manufacturer. (Although I wondered how the same Plan would regard other errors such as omitting a, for example, “Keep Refrigerated” statement, also a CCP ??, ie where is the "significant" risk level set ??)

I will add that if there are any published (eg IT) examples of a YES in a food manufacturing HACCP plan they seem to be very rare, I was surprised by this in the sense that I expected to find many. This made me wonder as to the interpretation. Further comments welcome.

@ Susan - Thanks for the comments. Indeed the Australians are obviously very active in this area. You might also be interested in this thread I think -

http://www.ifsqn.com...amp;#entry16228

Rgds / Charles.C

[hSusan]

Thanks Charles - very useful discussion - am downloading that comparative article now!

Also, Australia has just completed the AFGC allergen guide review (the document I referred to earlier) - so thought I'd upload it here for everyone's reference. They're introducing something called VITAL - I haven't got a handle on it yet, will be interesting to see the discussion in the Oz food industry about this. (judging from the polls there aren't a lot of Australians on IFSQN so maybe we won't be seeing it here - unless perhaps non Australian IFSQN members find this an interesting & useful tool)

Cheers
Susan

Attached Files

•  Allergen_Guide_2007.pdf   588.14KB   55 downloads
•  Allergen_pamphletDL.pdf   235.96KB   77 downloads

[Charles.C]

Dear Susan,

Thanks for this very nice document(s). I wish they might have included a sample HACCP plan also but all official bodies (except US maybe) seem to currently be worried that it will immediately be used as a standard reference.

Rgds / Charles.C

[Simon]

Also, Australia has just completed the AFGC allergen guide review (the document I referred to earlier) - so thought I'd upload it here for everyone's reference. They're introducing something called VITAL - I haven't got a handle on it yet, will be interesting to see the discussion in the Oz food industry about this. (judging from the polls there aren't a lot of Australians on IFSQN so maybe we won't be seeing it here - unless perhaps non Australian IFSQN members find this an interesting & useful tool)

Susan fantastic allergen reference document regardless of being Oz specific. I'm sure members will comment regardless, if they see it. Anyway if you're feeling a bit lonely you can always invite some of your Oceanic colleagues to the forums.

Regards,
Simon

[hacked]

i think an allergen is consdered a hazard and should be included in the HACCP plan under raw materials assessment. it is also a good practice that food producing companies practice raw material audit even if it is not included in their HACCP plan.

[hSusan]

Susan fantastic allergen reference document regardless of being Oz specific. I'm sure members will comment regardless, if they see it. Anyway if you're feeling a bit lonely you can always invite some of your Oceanic colleagues to the forums.

Regards,
Simon

Have invited quite a few people already :-) Unfortunately I suspect most are too busy running hard to be able to use IFSQN. I'm a little luckier than most at the moment being able to spend any time on CPD-type activities!

Well I've recently wake-up call re. allergen management and thought I'd share it with the forum. I recently was briefed about a food manufacturer who is taking the approach of labelling with "may contain" statements except for 2 allergens that they've identified as higher risk for them. Due to this, their HACCP plan does not contain any analysis of their other allergen hazards (milk & egg). They apply controls such as allergen cleans only to the two prioritised allergens.

As a consumer who is allergic to dairy foods I'd always taken the 'may contain' statements as a help rather than a strict rule - ie. if I had a choice, I'd avoid a product with such declarations. But, as those with allergies know, you often don't have much choice at all, and if you don't have a history of anaphylaxic response, then you trade off the risks on a case by case basis.

(to clarify - the milk allergy results in breathing difficulties, rhinitis & congestion that has generally led to chest infections when not treated. Initial treatment is with antihistamines - but all available antihistamines contain lactose - which is not particularly helpful to an auditor with lactose intolerance).

UNtil now I thought the risk was fairly minimal - all the manufacturers I knew were using the statement to cover fairly minimal residual risk levels - having applied GMP controls to all allergens (within reasonable limits) and at least recognising all allergens in their hazard analyses. However this manufacturer clearly does not do even this - all the risk is covered by the labelling declarations.

Based on this there could be anything from trace amounts of allergens to significant amounts, in their products, for all I know.

Now, if we put aside the 'nice' considerations (ie. that manufacturers 'should' minimise use of these statements so that people with allergies are not unduely restricted), the remaining question (for me) is whether the above approach is consistent with the HACCP methodology. Why, why not?

[Simon]

Have invited quite a few people already :-) Unfortunately I suspect most are too busy running hard to be able to use IFSQN. I'm a little luckier than most at the moment being able to spend any time on CPD-type activities!

Ah well thanks for trying. I never give up trying to get new members.

If I buy a chocolate bar with a “may contain” statement on is the manufacturer saying we cannot control our process or is it that some of the ingredients cannot be trusted. Either way it’s wimping out. Warning may contain killer bacteria.

Maybe someone more knowledgeable can help you on the use of “may contain” and its consistency with the HACCP methodology.

Regards,
Simon