Manufacturers have less than a year to meet new allergen labelling rules which will increase pressure to prevent cross- contamination, particularly from the use of 'rework material' not in the product formulation.
Having efficient recall systems for contaminated products that carry no warning or the use of 'may contain' labelling was no longer enough, said Kathryn Gilbertson of Greenwoods Solicitors at a Society of Food Hygiene Technology meeting last month. "It is not a general insurance policy to protect you. In fact, it is more of a problem than it is worth. Due diligence defences are very hard to come by when you have made someone very poorly."
The Food Labelling (Amendment) Regulations 2004, which took effect on November 25, will require clear labelling for about 12 allergenic ingredient types (see below) within a year. In effect, manufacturers have 12 months to clear stock.
The 'big eight' allergens are said to account for 90% of all allergic reactions, which can cause death.
The rules will require good hazard analysis critical control point (HACCP) plans, particularly to prevent mis-labelling, and scrutiny of ingredients suppliers for potential cross-contamination.
Hazlewood Grocery's technical director Adrian Regan, said that supermarkets expected suppliers to adopt barcode verification.
Sainsbury's head of product safety, Alison Austin, stressed the importance of keeping product specifications up to date. Equally important was traceability, she said: "Don't be surprised if you get a lot more requests to go a lot further back."
The regulations apply only to pre-packaged items and, as most allergenic reactions resulted from catering, there was now "a real conflict in labelling laws", said Gilbertson.
Hazel Gowland, food adviser to the Anaphylaxis Campaign, added: "The deaths are coming from take-aways on Friday nights, not ready meals."
New rules mean clear labelling for:
? Cereal containing gluten
? Crustaceans
? Eggs
? Fish
? Peanuts
? Soybeans
? Milk
? Nuts
? Celery
? Mustard
? Sesame seeds
? Sulphur dioxide (SO2) and sulphites at more than 10mg/kg or 10mg/l as expressed as SO2