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Does anybody have experience of processing chestnuts at their site?

allergen labelling food law

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#1 Lesley.Roberts

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Posted 14 November 2018 - 11:26 AM

Hi all

 

Does anybody have experience of processing chestnuts at their site?...

 

Whilst I know they are not classed as an allergen (under EU legislation) I understand that they may cause an allergic reaction.

 

UK members will be aware of the recent issues surrounding Pret a Manger product labelling (ie. whilst they were following “the law” on food labelling their measures still failed to prevent customer illnesses & death).

 

Using this logic my view is that, if we are unable to prevent cross contamination from chestnut residue (and I don’t know how we would test for this as I don’t think there is currently an allergen kit?) customers should be advised that their products “may contain” this residue so they are fully aware of this small, but significant risk. 

 

Maybe not a legal requirement, but a moral one considering our products are sold worldwide to industrial customers.



#2 Philip Jones

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Posted 14 November 2018 - 11:47 AM

Hi Lesley

An interesting conundrum, however I personally feel that it is ultimately up to the medical profession and other professional bodies to decide with the government what needs to be declared. Clearly any food traces which could cause anaphylactic shock should be declared, but somewhere, someone is alergic to something. Turning that around, everything is allergic to somebody (if you forgive my hyperbole).

I just did a quick look on the anaphylaxis campaign website and just at random, they said that although peanuts soya and lupin are well known legume allergies, all legumes can cause an allergic reaction, including (their examples)

Lentils

Chickpeas

Green peas

Black-eyed peas

Kidney beans

Haricot beans (navy beans)

Adzuki beans

Butter beans (lima beans)

Broad beans (fava beans)

Fenugreek

Cannellini beans

Flageolet beans

Pinto beans

Borlotti beans

Mange-tout.

 

I am not out to start a vendetta against vegetables, it is purely this list came to hand.

Essentially (they say) "Any food containing protein has the capability of causing an allergic reaction"

Obviously it is up to all companies to review their moral position in the light of the Pret a Manger incident, but I would be very cautious about going it alone in declaring more than legally required. I would worry that declaring extra items suggests "free from others" whicj may not be the case.

No doubt others will have their own views.



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#3 Lesley.Roberts

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Posted 14 November 2018 - 12:09 PM

Hi Lesley

An interesting conundrum, however I personally feel that it is ultimately up to the medical profession and other professional bodies to decide with the government what needs to be declared. Clearly any food traces which could cause anaphylactic shock should be declared, but somewhere, someone is alergic to something. Turning that around, everything is allergic to somebody (if you forgive my hyperbole).

I just did a quick look on the anaphylaxis campaign website and just at random, they said that although peanuts soya and lupin are well known legume allergies, all legumes can cause an allergic reaction, including (their examples)

Lentils

Chickpeas

Green peas

Black-eyed peas

Kidney beans

Haricot beans (navy beans)

Adzuki beans

Butter beans (lima beans)

Broad beans (fava beans)

Fenugreek

Cannellini beans

Flageolet beans

Pinto beans

Borlotti beans

Mange-tout.

 

I am not out to start a vendetta against vegetables, it is purely this list came to hand.

Essentially (they say) "Any food containing protein has the capability of causing an allergic reaction"

Obviously it is up to all companies to review their moral position in the light of the Pret a Manger incident, but I would be very cautious about going it alone in declaring more than legally required. I would worry that declaring extra items suggests "free from others" whicj may not be the case.

No doubt others will have their own views.

 

 

 

 

Hi There

 

 

Thank you so much for your quick response & I fully agree - allergens are a really complicated subject! 

 

 

There is also perception vs. fact - I just recently read an article in a medical journal that said that of the 20% of population that claim to have a food allergy, only 3-4% really do have an allergy.

 

 

Luckily our products are not for retail sale & therefore changes to packaging labelling wouldn't be necessary. 

 

 

Furthermore there are no beans/pulses currently processed on site so no risk there.

 

 

However at a site that currently only processes fruit I believe that our industrial customers would not expect to find chestnut residue and, as this is a potential allergen, it would be prudent to inform them so they can decide if they consider this to be a risk to their consumers. 



#4 pHruit

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Posted 14 November 2018 - 12:11 PM

Using this logic my view is that, if we are unable to prevent cross contamination from chestnut residue (and I don’t know how we would test for this as I don’t think there is currently an allergen kit?) customers should be advised that their products “may contain” this residue so they are fully aware of this small, but significant risk. 

I think the challenge here is that it raises the question: where do you draw the line?
In principle it's possible to have an allergy or a sensitivity to a truly vast range of foodstuffs. Should we all be attempting to control and assess all possible cross-contamination of every foodstuff in our facilities? If so, we surely then also need to perform the same risk assessment for our supply chain. And our packaging will need to expand to fold out to A1-size to incorporate a vast "may contain" list.

But is it helping our customers and consumers?

My experience of consumers with particular allergies, especially where they are unusual ones, is that they are pretty diligent and will go out of their way to ascertain suitability for themselves by asking questions. It's their allergy and they are the ones with responsibility for managing it, so as I see it our responsibility is to provide accurate and clear answers where we can.

For example, in a previous role I was passed a question from customer services, where a consumer with an allergy to pear skin was asking if they could safely drink a pear juice product. Obviously we didn't have a risk assessment on the probability of pear skin traces being present in the juice, but even a rudimentary knowledge of the production process suggests the probability is very high.

Personally if I was allergic to part of a fruit I'd probably avoid the whole thing, but it's the consumers choice (and also possibly more of a dietary sensitivity than an allergy) and we do what we can to assist them.

 

The only thing I'd specifically recommend in the case of Chestnuts is to check any "nut free" requirements/agreements that you may have with other customers if you're doing any sort of contract packing / ingredient supply for major brands or retailers, as some of them have pretty strange ideas about what is included in their list of nuts ;)



#5 aaallen

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Posted 14 November 2018 - 04:19 PM

Lesley,

 

Since not all allergens have ELISA testing available, could you validate cleaning with a protein swab after chestnuts? 



#6 moskito

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Posted 22 November 2018 - 04:40 PM

Dear Lesley,

 

IMO the politics has to decide which precentage of a population they want "to protect from food allergies". In the EU they have decided to cover 90-95% by regulating 14 allergens/intolerances. In other countries the allergens and the numbers of allergens differ. Until now politicians avoid to set legal limits due to lack of qualified methods working under (all) different conditions.

Nevertheless declaration and "may contain" advises should follow the legal frame. Otherwise you have to extend "may contain" to any possible allergen. What is if you handle chestnut and apple on a site in the EU and you included only chest nut in the cross  contact advise? Why do you as the FBO has decided to protect chestnut allergy and not the apple allergy sufferers, even both allergen might be present in ppm amounts? Where to find an end?

 

Uncertainty by measurement:

e.g ELISA is using antibodies. The frist question how these antibodies are produced? Against which mixture of "food" - origin, heat treated or not, monoclonal or polyconal etc etc. 

So it can happen that one test can detect an allergen before heat treatmant, but not in the finished product. If you are going to LOD/LOQ the matrix and extraction conditions become very important -and, and

-> manufacturers can minimized the allergenic risk, but you never can be sure..

e.g. PCR - the target molecule is not that which causes allergic reaction, but semiquantitative PCR can be helpful

e.g....other methods

 

but...at the end such tests will be developed and offered only if there is a market

 

Finally it make sense to stick to the legally defined allergen. There is sufficient uncertainty.

 

Rgds

moskito



#7 Lesley.Roberts

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Posted 22 November 2018 - 05:53 PM

Thank you to everybody who gave advice on this.

 

Unfortunately as intersite transfers are common across our company & chestnuts are considered nuts in USA this would mean a change in labelling for our USA customers. 

 

As one of our USPs is that we don't currently process nuts at our sites this would involve a major change for our customers so I think that's a "no" to chestnuts for the present time.



#8 SQFconsultant

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Posted 18 December 2018 - 12:28 AM

Interesting dilema as Chestnuts are considered a tree nut in the USA and thus an allergen.

 

But I just found this product on Amazon ---- Clement Faugier Gournet Chestnut spread from France that does not list Chestnut as an allergen (yes, of course it is on the label, however not "declared."

 

Considering that product sold in a country require allergen alerts, this product is in violation for the US market.

 

You would ask for a Chestnut Oil test kit.


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#9 Scampi

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Posted 18 December 2018 - 03:22 PM

here is the label for a national hazelnut spread available in USA and Canada. NOTE there is an allergen declaration on the label

 

 

https://www.google.c...CAYQBg..i&w=800


Because we always have is never an appropriate response!





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