In a ‘A Vision for Allergen Management Best Practice in the Food Industry' the FDF says that, while allergen management had increased food safety for affected consumers, divergent standards applied by manufacturers due to the absence of an agreed approach to risk assessment had led to problems.
"This has been reflected in a considerable expansion of precautionary labelling and a concommitant reduction in consumers' trust, resulting in risk taking," said the paper.
In practice this means that shoppers may take risks because they assume phrases such as 'may contain nuts' were just being used as a legal safety blanket, as they are so ubiquitous.
One issue, according to leading food manufacturers contacted by FoodManufacture.co.uk, is that the biggest food retailers have adopted slightly different policies on advisory labelling: while some advise suppliers to use statements such as 'made in a factory handling nuts', others - notably Sainsbury's - ask manufacturers to use phrases such as 'not suitable for coeliacs'.
Risk-based approach
The FDF paper proposes a shift from a hazard-based approach to a more consistent risk-based approach whereby manufacturers carefully assess the risk of cross-contamination with allergens and only use 'may contains' terms where this risk cannot be controlled.
Rachel Ward, chair of the steering group, said: “We hope that this paper will fuel the debate on policy implications amongst all stakeholders involved. Application of allergen management principles is still inconsistent. Individual manufacturers are currently interpreting risk in the supply chain differently as there are no agreed approaches to perform risk assessment to a common standard."
Thresholds and action levels
Sue Hattersley, head of the food allergy branch at the Food Standards Agency (FSA) said allergen management and labelling would be easier for firms once thresholds for the unintentional presence of allergens such as milk, peanuts and egg were established.
“The FSA recognises the importance of developing internationally-agreed allergen management thresholds.These will provide a consistent basis for industry practice and, more importantly, will give food allergic consumers confidence when using food labelling information to make their food choices. The Agency is keen to continue to work with all those involved to help realise the vision set out in this paper.”
Anaphylaxis Campaign chief executive Lynne Regent said she hoped a more risk-based approach would minimise the use of unnecessary precautionary labelling and make “shopping for food allergic individuals a safer and less stressful experience.”
Legal minefield
At Food Manufacture’s conference on allergen management earlier this year RSSL's allergens expert Simon Flanagan said the lack of thresholds made enforcement very challenging: “There was a recall recently on dark chocolate that contained milk. It did actually have a 'may contain' label but it was recalled anyway because it contained 'too much' milk. But how much is too much?”
Legally defined thresholds would provide firms with action levels to work to, plus defined levels for enforcement. They should also reduce 'may contain' labelling.
However, in the absence of official EU thresholds for allergens with the exception of gluten, many UK food manufacturers are working to unofficial limits or using the threshold-based Australian VITAL scheme as a guide, one source told FoodManufacture.co.uk.
"If we are not going to have thresholds in the EU for five years, what are we supposed to do in the meantime?"