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Allergens – food service responsibilities

2019; Wiley; Volume: 33; Issue: 4 Linguagem: Inglês

10.1002/fsat.3304_15.x

2689-1816

Asthma and respiratory diseases

Food Science and TechnologyVolume 33, Issue 4 p. 56-59 FeaturesFree Access Allergens – food service responsibilities First published: 13 December 2019 https://doi.org/10.1002/fsat.3304_15.xAboutSectionsPDF ToolsExport citationAdd to favoritesTrack citation ShareShare Give accessShare full text accessShare full-text accessPlease review our Terms and Conditions of Use and check box below to share full-text version of article.I have read and accept the Wiley Online Library Terms and Conditions of UseShareable LinkUse the link below to share a full-text version of this article with your friends and colleagues. Learn more.Copy URL Share a linkShare onFacebookTwitterLinkedInRedditWechat Sterling Crew reviews the proposed changes to allergen labelling rules and their potential impact on food businesses in the retail and catering sectors. Food allergy is recognised as an important food safety issue, which rightly commands media, regulatory, industry and consumer attention. Sufferers of food allergies or food intolerances must avoid eating problem foods and rely on emergency treatment in case of exposure. The dietary restrictions which follow can become a blight on affected individuals and their families. In some individuals with severe forms of the condition, life threatening reactions can be prompted by even small traces of the trigger foods. An allergic reactions may range from relatively short-lived discomfort to anaphylactic shock and fatality1. Recently, widely reported deaths of teenagers with food allergies have highlighted the human impact of the condition and the importance of clear, accurate labelling and effective allergen management. Food allergic reactions are hyperactive responses of the immune system to generally innocuous substances. They are typically an immunoglobulin E (a type of antibody) reaction caused by the release of histamine but also encompassing non-IgE immune responses. This mechanism causes allergies to typically give an immediate reaction to foods and may involve anaphylaxis. Non-IgE reactions are characterised by an immune mediated response not involving IgE. This may occur some hours after eating the implicated food which can make diagnosis challenging. Food intolerance is a detrimental reaction, often delayed, to a food or a compound found in foods that produces symptoms in one or more body organs and systems. In practice the term generally refers to reactions other than food allergy. The most common food intolerance in the UK is lactose intolerance. Food intolerances are rarely life threatening but can have a big impact on sufferers’ day-to-day lives. More than 160 foods have been identified which can cause allergic reactions2. The diagnosis of an allergy is usually achieved by reviewing a person's medical history and finding a positive result for the presence of allergen-specific IgE when conducting a blood or skin test. People who suspect that they suffer from a food allergy should undergo tests to determine if it is a real allergy and what substance is the cause. It is estimated that around 10 to 20 people die from a food allergic reaction in the UK each year. The exact number is not known because some allergy deaths are recorded as asthma-induced. In the developed world it is estimated that around 4-8% of people have at least one food allergy. More than 160 foods have been identified which can cause allergic reactions. In a recent FSA survey3, it was found that 79% of respondents reported no food hypersensitivity while 21% reported having an adverse reaction to consuming certain foods. The most common reported reactions were food intolerances (12%) followed by food allergies (5%). Natasha's law A new law protecting allergy sufferers has been introduced following the tragic death of 15-year old Natasha Ednan-Laperouse. Natasha died of anaphylaxis after collapsing on board a flight to Nice in 2016. She had a severe allergic reaction after eating sesame seeds in an artichoke, olive and tapenade Pret A Manger baguette bought at Heathrow Airport. Natasha and her family were aware she was allergic to sesame and took precautions to avoid contact. The bread contained ground sesame seeds, which were not listed on the label and there was no allergen advice. At the time, there was no legal requirement for Pret A Manger to list allergens because of reduced labelling requirements for food produced on site, called pre-packed for direct sale (PPDS). For these foods it was sufficient for general allergen warnings to be posted around the shop at point of choice, rather than on the packaging, and for specific advice on 14 prescribed allergens to be collated and given orally by staff. Prepacked foods vs PPDS Pre-packed foods any food put into packaging before being placed on sale. Pre-packed foods must have an ingredients list in descending order of weight and allergenic ingredients must be emphasised every time they appear in the ingredients list. Food is prepacked when it is either fully or partly enclosed by the packaging, cannot be altered without opening or changing the packaging and is ready for sale. Food pre-packed for direct sale (PPDS) Although there is there is currently no legal definition, PPDS has been exempt from the above requirement if it is made, packed and sold on the same premises. This could include sandwiches, baguettes, salads in boxes etc. It is expected, in these circumstances, that the customer will speak to the person who made or packed the product to ask about ingredients. Currently for these products, allergen information can be provided in the same way as for non-prepacked (loose) foods through signposting at point of choice to encourage customers to ask staff about allergens. The coroner overseeing the inquest into Natasha's death, criticised Pret A Manger for having inadequate labelling on packaging in terms of visibility and giving insufficient attention to monitoring food allergy. He felt that Natasha was falsely ‘reassured’ by wrappers and store signs. A complaint log for the company from between July 17, 2015 and June 29 2016 showed nine cases of sesame-related allergy incidents. The coroner added that the tragedy of Natasha's death ‘should serve as a watershed moment to make meaningful change to save lives’ and wrote to the Environment Secretary asking if big businesses like Pret A Manger should benefit from food labelling exemptions meant for small sandwich shops. Natasha's parents began a campaign for ‘Natasha's Law’ to require all food businesses to include full ingredients labelling on PPDS foods giving food allergy sufferers greater confidence in making safe food choices. Consultation and legislation Following Natasha's death and the coroner's comments, the FSA invited food businesses and allergy sufferers to have their say on four options put forward to improve the way allergy information is provided on PPDS: Mandating full ingredient list labelling. Mandating allergen-only labelling on food packaging. Mandating ‘ask the staff’ labels on all products, with supporting information for consumers available in writing. Promoting best practice around communicating allergen information to consumers. After the consultation, the FSA recommended the ‘Mandating full ingredient list labelling’ option supported by the Environment Secretary. The legislation was passed on 5th September 2019, with a two year implementation period for businesses to adapt to the change. From 1 October 2021, the way food businesses must provide allergen labelling information for PPDS food will clearly change. This law currently covers England, but it is anticipated that similar arrangements will follow in the devolved nations. To help food business operators implement the change, the FSA aims to publish A Technical Guidance in December 2019. However, the lack of a legal definition for PPDS is presenting difficulties. The current FSA position on PPDS is that it applies to any foods that have been packed on the same premises from which they are being sold4, 5 whilst the industry has suggested that there should be a distinction between foods selected by the customer without a member of staff helping, and those foods only served from behind a counter. The FSA was due to issue a complete definition with guidance on 1st October 2019, however, after concerns raised by industry, the decision has been deferred until there is full stakeholder engagement. This will allow greater clarity on the types of food covered and how they are made available to the consumer. The new law states that food businesses will need to include a full ingredient label on PPDS foods and any allergenic ingredients must be emphasised in bold, italics or a different colour. The changes will cover labelling requirements for foods that are prepared and packed on the same premises from which they are sold, for example, a packed sandwich or salad made by staff earlier in the day and placed on the shelf for purchase. In contrast, the current law exempts PPDS food from even carrying allergen information on the packaging. This does not affect foods, such as a sandwich or baguette, made to order in front of customers. These types of food do not currently require a label and this will not change under the new proposals; it is assumed a conversation will have taken place between staff and customers which should include discussions about allergens. To facilitate these conversations, premises require a sign nearby to prompt customers to ask about allergens. Under the new legislation, if baguettes are wrapped and packed in advance, whether or not to go on a shelf where customers self-select, or kept behind a counter, they will need to have a label. The label will have to list all ingredients and highlight the 14 major allergens. The EU Regulation on Food Information for Consumers, which came into force in 2014, lists the 14 allergens that need to be identified if they are used as ingredients (Table 1). This is not an exhaustive list because more than 160 foods have been identified which can cause allergic reactions. These additional foods need not be identified in bold, as they are present in traces which need not be identified on a wrapper. Table 1. The 14 allergens that must to be identified if they are used as ingredients6 1 celery 2 cereals containing gluten – including wheat (such as spelt and Khorasan), rye, barley and oats 3 crustaceans – such as prawns, crabs and lobsters 4 eggs 5 fish 6 lupin 7 milk 8 molluscs – such as mussels and oysters 9 mustard 10 tree nuts – including almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts 11 peanuts 12 sesame seeds 13 soybeans 14 sulphur dioxide and sulphites (if they are at a concentration of more than ten parts per million) The new legislation: greater protection for allergic consumers? The aims of the new legislation are admirable as is the advocacy made by Natasha's family. At face value the proposed legislation should provide greater protection for allergic consumers. However there are concerns that if it is implemented too hastily without a full consideration of the implications, it could create a more unsafe situation. A significant number of the businesses which would now come under the scope of the legislation are micro or small sized enterprises. They may find it too much of a burden to produce a full accurate ingredient label. After the fallout of the inquest into Natasha's death, Pret A Manger has responded emphatically to the criticism. All of its freshly made sandwiches, salads, baguettes and soups are now labelled on pack each day with a full list of ingredients including the presence of any of the 14 EU declarable allergens highlighted in bold. This is achieved by using individual recipe cards, which enable employees to prepare food in kitchens on site and print off a bespoke label providing an electronic record of each product that leaves the kitchen. All the company's 391 stores have had a refit with new equipment and technology to facilitate allergen management and labelling. This major endeavour by Pret A Manger highlights the nature of the problem. Large restaurant chains have the expertise, resources, technical capability and sophisticated Food Safety Management Systems with robust HACCP programmes to enable them to specify and monitor allergen management and labelling performance. Even so, the packs often still have warnings that because the foods are made where allergens are present, there is no guarantee that foods are free of an allergen not listed on the label. The vast majority of small foodservice outlets do not possess this capability and may simply buy in pre-packed foods instead of preparing them in-house, because the onus of labelling would then rest with the manufacturer. Alternatively they may decide to stop wrapping food which may mean more risk of contamination and cross-contact. It could be argued that the new labelling requirements might introduce a greater risk and give allergic consumers a false sense of security. There could be an additional hazard of an incorrect ingredients list on the packaging from human error or from cross-packing when the right label is put on the wrong pack. This could have disastrous consequences if an allergen is under-declared. It is also compounded by the additional risk of using an incorrect recipe or the addition of a wrong ingredient. The FSA regularly reports product withdrawals due to allergen mislabelling. Indeed allergen issues account for the majority of the published withdrawals7. These are often from large retailers and manufacturers who have some of the country's most sophisticated Food Safety Management Systems and best resourced technical capability. If they struggle with allergen labelling, it demonstrates the nature and scale of the challenge facing small retail and catering businesses. Skin testing for allergic reactions to foods There is concern that the new labelling requirements might not be an improved alternative to an engaged conversation with shop staff, and in fact may well actually discourage this important dialogue taking place. Although there is an expectation that the customer is still able to speak with the person who made or packed the product to ask about ingredients, they may chose not to do so and simply trust the label. A more effective, safer deliverable approach might be mandating ‘ask the staff’ labels on all products, with supporting information for consumers available in writing. However, some people may feel inhibited about asking staff for information. Although this option was selected, together with a mandatory written information sheet, as the best by industry, consumers supported the provision of more written information on allergens and labelling of all ingredients. Precautionary allergen labelling Foodservice businesses have a responsibility to minimise the risks to allergen-susceptible consumers of their products. As part of their allergen communication risk strategy a decision needs to be made on whether precautionary allergen labelling (PAL) is required. It should be based on risk assessment and risk management steps and allergic individuals should be warned about allergens that may be present unintentionally. It may not be possible in every case to guarantee foods from an outlet are free from allergens due to a significant cross-contamination risk from products, people and the environment. The aim is to enable consumers at risk to make an informed decision to protect themselves and those in their care. Allergic individuals must be informed about which allergens are present as ingredients, but in catering premises they may not be told if they ask about those that could be there in traces, unintentionally from cross-contact or cross-contamination. The value of allergen labelling other than for intentional ingredients is controversial. In the UK, longstanding industry practice emphasises that the use of advisory ‘may contain’ labelling should be the last resort of a series of assessments. It should not be used as an alternative to good manufacturing and catering practice and relevant controls. In general, the principles referred to for product formulation and avoidance of unintended allergen presence by manufacturers apply equally to foodservice providers. Such labels do not help allergic consumers cope with their condition and may mean their food choices become ever more restricted. Responsibly applied PAL should be seen as a last resort, following a thorough allergen risk assessment of each product. In response to the problems posed by accidental inclusion of allergens and the lack of resources and confidence to implement appropriate control systems, many more food service operators may adopt PAL in the future and chose a defensive labelling approach. Enforcement The introduction of legislation cannot on its own deliver safer food for allergic sufferers; it has to be effectively communicated to business and enforced. The financial position of local authorities will affect the delivery of the new allergen labelling legislation. The economic climate has resulted in a decrease in enforcement visits and food sampling programmes by councils. There needs to be a consistent, resourced approach across the UK. The allergen labelling requirements could become a component of the Food Hygiene Rating Scheme8 if the officers involved were given training and guidance. There could be a future facility for approved private sector organisations to carry out allergen management and labelling visits or even rating inspections freeing regulatory authorities to focus on their important enforcement role8. There are however obvious local authority operational and political concerns about the ‘privatisation’ of this service. A number of independent third party certification schemes are available which could provide additional assurance. Conclusions In light of recent tragedies the food industry should be doing more to keep allergic customers safe. It makes sense for those businesses in food service to review the robustness of their approach to the management and labelling of allergens. Allergen management in most foodservice businesses is demanding as typically sites are handling multiple allergens with frequent change overs. Consumer demand for free-from, vegetarian, vegan and allergen controlled products increases the complexity. However continuing with the current ‘status quo’ is not a realistic option. Consumers must have the information they need to make the right choice. As management of a food allergy or intolerance requires the strict avoidance of the food linked with the sensitivity, the trustworthiness of both written and oral information is critical. This will present challenges especially for smaller food companies, where food handlers are often transient and low paid with a low level of education and training. However, all food business operators will have to raise the allergen awareness and training of their staff. It is my opinion that the safety of food can be best assured by encouraging a dialogue between the allergic consumer and the food business, including best practice around communicating allergen information to consumers, underpinned by a positive food safety culture9 that drives food handler behavioural practice. We do not want to inadvertently create a situation that could potentially be more dangerous than the current position. Sterling Crew FIFST, FCIEH, FRSPH, CEnvH, CSi. Co-Founder of Kitchen Conversation Managing Director SQS Ltd. Chair of the Food Authenticity Network Advisory Board. Strategic Advisor Shield Safety Group and Dynamic Risk Indicator. Chair of the IFST Food Safety Group. Independent Scientific Advisor and Board member of Campden BRI. Audit Governance Board member Eurofins auditing. Scientific. Advisor for Olio. Email sterlingmcrew@aol.com REFERENCES 1Walker, M., Gowland, H. 2017. Food allergy: managing food allergens. In: Analysis of Food Toxins and Toxicants (eds Wong, Y.-C., Lewis, R.J.), pp. 711-742. John Wiley & Sons, ISBN: 978-1-118-99272-2 2Cox, L., Williams, B., Sicherer, S., Oppenheimer, J., Sher, L., Hamilton, R., Golden, D. 2008. Pearls and pitfalls of allergy diagnostic testing: report from the American College of Allergy, Asthma and Immunology/American Academy of Allergy, Asthma and Immunology Specific IgE Test Task Force. Annals of Allergy Asthma & Immunology 101(6): 580– 592 3 UK Food Standards Agency. Secondary Analysis: Consumers with Food Hypersensitivities. Wave 5. The Food and You Survey. October 2019. 4 UK Food Standards Agency. Advice for caterers on allergy and intolerance. December 2018. 5 UK Food Standards Agency. Providing allergen information for non-prepacked foods. 6https://allergytraining.food.gov.uk/english/rules-and-legislation/ 7Crew, S.M. 2017. Managing food safety withdrawals and recalls. Food Science and Technology 31(2), 32- 35 8Crew, S.M. 2019. First-rate facilities. Food Science and Technology 33(2), 46- 49 9Crew, S.M. 2014. Delivering a food safety culture. Food Science and Technology 28(4) Volume33, Issue4December 2019Pages 56-59 ReferencesRelatedInformation