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Keeping allergens under control

04 August 2020

Phil Brown argues that confusing guidance, weak legislation, and multi-function food production sites can pollute the supply chain. He also looks at the steps that factories can take to implement tighter hygiene controls. 

Data recently published by The New England Journal of Medicine suggests that the Covid-19 virus can survive for several hours on contact surfaces or objects. Making vigorous enforcement of good hygiene, sanitation, and Good Manufacturing Practices (GMPs) vital in all food production areas. By taking steps to mitigate all cross contamination and physical risks, manufacturers can allay a wide range of consumer fears.

Food and beverage manufacturers have a responsibility to identify allergens contained in their products. This responsibility extends to isolating them from other non-allergen products processed in the same facility.

Although producers are active in ensuring they source allergen-free products, problems may still occur on the supplier side – especially when sourcing from multiple or multi-function sites. 

For example, dairy-free products are still often produced at sites that make dairy products. Although thorough clean downs can flush away residual dairy products, this method cannot be relied upon as being totally foolproof.

Common tactics
Planning production schedules to isolate products containing allergens is a common tactic in manufacturing plants where a dedicated line cannot be allocated. The storage of ingredients should also be separated. Gluten in particular has become a major source of concern, with many sites introducing segregated gluten-free stations and changes of work clothes for operatives. 

EU law lists 14 allergens that should be declared on pre-packed and non-pre-packed food and drink. The list comprises celery, cereals that contain gluten, fish and crustacean shellfish, eggs, milk, lupin, molluscs, mustard, peanuts, tree nuts, sesame, soybeans, and sulphur dioxide & sulphites. 

With the exception of ‘gluten-free’, there is no specific UK or EU legislation covering ‘free-from’ claims. A statement of gluten-free may only be made where the food sold to the final consumer contains no more than 20 mg/kg of gluten. This means a gluten-free product may not be entirely rid of the protein. The same could be true when vegan claims are being made. 

Guidance issued by the Food & Drink Federation (FDF) in February states that “At present, there is no legal definition of what constitutes ’Allergen’-Free/Free-From (except for gluten-free) and making such claims is not mandated in legislation. These claims are therefore used on a voluntary basis, however are regulated in accordance with General Food Law requiring the provision of safe food.” The FDF also confirms that allergen-free and vegan are separate claims, with the report stating “There is a clear risk to allergic consumers who treat ‘vegan’ claims and allergen absence claims as equivalent, and this has potential serious health implications.” 

This makes the issue for manufacturers increasingly confusing. Greater clarity is clearly needed. Currently, food businesses can provide allergen information for pre-packed food for direct sale (PPDS) by any means they choose, including orally by a member of staff. However, the Food Information (Amendment) (England) Regulations 2019 has laid out new rules. From 1 October 2021, PPDS food will need to have a label with a full ingredients list with allergenic ingredients emphasised within it.

Sparc offers an integrated label inspection system in its x-ray and metal detector conveyor and checkweighing combination inspection systems. As well as actively inspecting for allergen ID codes, these systems also check product descriptions, bar codes, lot numbers and date codes. Checking for errors on the top, bottom, lid or pot of packaging. However, critical, label inspection forms just part of the allergen management process. Food manufacturers have a duty of care to ensure allergens, and cross contact contaminations are controlled and where possible eliminated from products and their supply chains.

With allergies being such a common chronic disease in Europe – 20% of sufferers live with a severe debilitating form of the condition – it is vital that food manufacturers perform allergen risk assessments on all elements of production, from raw materials to packing. Where products are targeted at specific groups of consumers, for example gluten, dairy and egg free, the assessment must be proportionate to the increased probability of harming those consumers.”

Phil Brown is managing director at Sparc Systems. 

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