Food Safety for SMEs: Allergen Control

This is the safefood Food Safety for SMEs podcast series presented by Dr Linda Gordon, safefood’s chief specialist in food science, which looks at the factors that shape the food industry on the Island of Ireland. In this episode we chat to James McIntosh, safefood's specialist in chemistry & toxicology and an expert in food allergens, about allergen control for food businesses from production to point of sale.

Transcript

Linda: Hi, I'm Dr. Linda Gordon, safefood's Chief Specialist in food science.

safefood is the all-island body responsible for promoting food safety and healthy eating. This is the safefood Food Safety podcast series where we look at the factors that shape the food industry on the island of Ireland.

This episode looks at allergen control and what food businesses need to think about from production to point of sale. We chat to our own Dr. James McIntosh, who is a specialist in chemistry and toxicology, and so is an expert on food allergens, what the law requires, and the practical implications of controlling them in a food business.

Hi James, and thanks for joining us.

James: Hi, Linda.

Linda: So we hear a lot about allergens these days. Why are they such a concern in food?

James: Well the incidence of food allergy has increased in recent years, and it's now thought that it affects something in the region of one to 2% of adults, and in and around five to 8% of children.

The reason there's a difference there is that a lot of childhood allergies are outgrown by roughly the age of eight.

But in addition to this, the prevalence of Coeliac Disease, for instance, is around 1% of the population. And as for the prevalences of the different food intolerances, we know that lactose intolerance affects around 5% of the population, but we simply don't know what the prevalence of the other food intolerances is.

Things like non-Coeliac gluten sensitivity, for instance. If we take a conservative estimate of the overall prevalence of food type sensitivity, that's the umbrella term for food allergy, food intolerance, and Coeliac Disease. And if we say that it's 15% of the population, which is a conservative estimate, then on the island of Ireland, this equates to something over 900,000 people.

So for food businesses, this represents a significant proportion of their customer base and something that they simply cannot afford to ignore.

Linda: What are the allergens that food businesses need to be worried about specifically?

James: Well as a food business, whether you're in manufacturing or catering, you have to inform your customers if any of your products contain any one of 14 food ingredients that can cause allergies or intolerances.

And these are, cereals containing gluten, namely wheat, rye, barley, oats, spelt, or kamut. Crustaceans, so things like prawns and lobster. Eggs, from whatever source. Fish, peanuts, soya beans, milk, again from any mammalian source, nuts, namely almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, and macadamia nuts. Celery, mustard, sesame, sulfur dioxide and sulfites at concentrations of more than 10 milligrams per kilogram of food or 10 milligrams per litre of food, in terms of the total S02 level, and lastly lupin and molluscs such as snails or oysters.

There are certain exceptions to the labelling requirements, so best check out the annex to regulation 1169 of 2011 if you want to be sure.

So if you manufacture pre-packed food products of the type that we get on our supermarket shelves, for instance, and use any of these foods as ingredients, they must appear highlighted on the ingredients list. Don't forget, there are six cereals containing gluten, and eight nuts, and these are what you must put on the ingredients list. In other words, you can't just say for instance, nuts. You must state the actual nut if it is one of the eight listed in the legislation.

All food businesses selling non-pre-packed foods, or foods sold loose as they're also called, must also provide this information. In the Republic of Ireland, this has to be provided in written form, such as on a menu or maybe on a notice board, while in Northern Ireland, the information can be imparted verbally to the customer filing a request.

Food businesses selling non-pre-packed foods should also remember that they could receive a request from a customer to provide other foods, as well, for health reasons. Just treat the request as you would a request to avoid any of the legislated and allergenic foods. Check the ingredients of whatever they have chosen to eat and determine if there is a risk of contamination with the allergen that they need to avoid.

Linda: Okay, so there's a lot that people need to think about there. But surely, allergens it's just the latest fad in terms of foods, though. I mean everyone seems to have an allergy or an intolerance or be avoiding some food product or other these days.

James: Well, there is no doubt whether the incidence of food allergy in particular is increasing. At the same time, a lot of people, for whatever reason, have chosen to follow 'free from' diets such as, for instance, 'gluten free' or 'dairy free'.

It's important to remember that the legislation is concerned with people who need to avoid food for health reasons. That's allergies, Coeliac Disease, and other food intolerances. You have no way of knowing which is which, although a customer with a food allergy, food intolerance, or Coeliac Disease, should engage more with the staff to get all the information they need to make a safe food choice.

Linda: What can be the consequences, then, for somebody who has a food allergy and if they accidentally eat the food that they're allergic to?

James: For somebody who has a food allergy, if they come into contact with that allergen, the consequences can be very severe, indeed. Particularly with regard to severe food allergies.

Now thankfully, severe food allergies are relatively rare. But unfortunately, when things go wrong, the cases have a habit of hitting the headlines and perhaps some of us remember some recent high-profile cases in the media where somebody died following exposure to an allergen in their food.

Besides that, for instance if somebody has Coeliac Disease, they can be sick for anything up to two weeks if they're exposed to gluten by accident. So you can imagine this has a significant effect on your quality of life, let alone your health as well.

Linda: Okay, so the consequences are quite serious, then. And this is something that food businesses can't ignore. And what about the kind of, you talked about what we need to put on labels. But what about those kind of, 'may contain nuts' type of notices and signs that we see on things. Should every food business put those on just in case?

James: Well 'may contain' is a form of what's called precautionary allergen labeling. Now this presents a dilemma for both customer and food business alike. There is no legislation governing its use. It was developed by the food industry to convey to customers the risk of contamination with particular allergen.

The evidence suggests it is now being overused, but the end user has no way of knowing how accurate a 'may contain' label actually is. Many caterers, for instance, just include this on their dishes as if it was an actual ingredient. Now this is well intentioned, but however it's actually wrong because you're only supposed to label a menu item with the actual allergenic ingredients.

Other caterers include the 'may contain' statements directly on their menu items after the allergenic ingredients. This is their choice and they're entitled to do so. A customer who needs to avoid allergens will engage with you on the potential for cross contamination with that allergen. This included any 'may contain' labels, so best keep a record of these so that you can pass this information on to your customer.

Linda: Okay, and so what can happen if a food business gets their allergen labelling wrong or they miss an allergen off their ingredients list or something, or they don't realise, maybe that one of the raw ingredients they're using contains an allergen; how will this impact on the business?

James: Approximately half of all the food product recalls over the last number of years have been due to incorrect allergen labelling. Now when you think about it, there's nothing fundamentally wrong with these food products. They're not strictly unsafe, it's just that the allergen labelling was incorrect and unless that product can be reworked, it will probably be destroyed following a recall.

From the consumer's perspective, they need to check the label if they have to avoid certain allergens. So if they don't see it on the ingredients list, they may very well take the chance and assume that it doesn't contain that allergen. Now if it does, they could become very ill depending on what the allergen is and their sensitivity and the amount they actually consume.

Similarly, in a catering scenario, a customer will make a choice on the basis of the information they get. So leaving out an allergenic ingredient gives them false information about that particular food choice.

Linda: Okay, so James, are there further legal implications if a food business gets it wrong in relation to allergens, beyond a recall of their product?

James: Yes, unfortunately there is. And particularly in the UK, there have been a number of cases recently where businesses have been fined for a number of reasons, the most common being providing false information on the allergen content of the foods they sell.

This is particularly true for the catering sector where customers have gone in and asked for, for instance, in one case I think it was an egg-free dessert and they were advised it was egg free, when in actual fact it wasn't, and the customer became ill.

But it's not just catering. We've had another case recently in Northern Ireland where a child got sick. Again, he had an allergy to egg, and he ate a bar, a pre-packed food product that did not have egg listed as an allergen in the ingredients.

So this is very costly for the companies involved, and of course the damage to the reputation is something that they could well do without.

We probably are more familiar with the recent press case in the United Kingdom, the results of which came through this year where somebody died following consumption of a bread product bought on site that contained sesame seeds, but there was no indication that it actually had sesame in it, even though at the time there was no obligation to do so.

The law now has now changed in the United Kingdom and it's going to be coming to force very shortly with regard to these specific type of food products. But, yes, in general for a food business, you need to be cognisant of the fact that if your customer gets sick or harm is done to them because you haven't controlled allergens properly, yes, you may find yourself at the wrong end of a Judge's ruling.

Linda: Okay, so it's worth then the food business putting the time into getting their label correct. It can be quite serious both for them and the customers if they get it wrong.

James: Absolutely.

Linda: So apart from labelling, what else does a good business need to do to make sure their food is safe for an allergy sufferer?

James: Well, the possibility of a food being contaminated by accident with an allergen, for instance, that's really the big risk for customers who have to avoid allergens. Food manufacturers can resort to precautionary allergen or 'may contain' labelling to tell customers that there is a risk of contamination. However, ideally, they should assess the risk of this actually happening and only resort to that precautionary allergen labelling if they think there's a real risk of the contamination.

A caterer should assist their customer in making a safe food choice based on the ingredients and then ask themselves if there is a chance of contamination with the allergen at any stage.

Remember, some allergens are more difficult to control than others. Ironically, gluten free, which is undoubtedly the most popular 'free from' choice for customers, is actually one of the most difficult if not the most difficult allergen to control. Just think of opening a package of flour in the kitchen. It's literally gone everywhere within a matter of minutes.

So caterers need to take this into account and just how easy it is to contaminate with certain allergens, particularly those that are volatile. Things like the flour, so lupin flour, gluten flour, et cetera.

Linda: Okay. You mentioned 'free from' there in terms of gluten free, but we see a lot of free from products nowadays in the supermarket. There could be a whole or half an aisle dedicated to those. So can you tell us more about how businesses, what they need to consider when they're doing that?

James: I think it's fair to say that your customers who have food allergy, Coeliac Disease, or food intolerances really welcome 'free from' choices and they will naturally gravitate towards these as they see it is almost a guarantee that the food is free from a particular allergen. Hence, the label 'free from'.

'Free from' choices are growing in popularity and food businesses are responding accordingly. Our research has shown that roughly half of all caterers now provide free from choices for their customers, which is a good thing.

However, as a food business, you need to remember that for the legislated food allergens, 'free from' means free from. This is essentially a zero tolerance approach and you can see why. For example, a customer with a nut allergy will trust a product or menu item that says 'free from nuts'. If that product did contain nuts, however, it would be putting that customer at risk. And depending on the level of nut in the product, the risk could be severe.

So make sure that 'free from' really means free from. The exception to this is the label 'gluten free'. This is undoubtedly the most popular 'free from' choice according to market research.

But food businesses need to be aware that the term 'gluten free' now has a specific meaning as defined in law, namely that the food product or menu item does not contain more than 20 milligrams of gluten per kilogram of the food. This may not present problems for food manufacturers, but how can the caterer know the final concentration of gluten in their menu items? This is important, as it has a knock on effect on the accuracy of the information they give to their customers.

Linda: Cross contamination must be a risk for many businesses, particular in a busy catering kitchen. Do you have any tips on how to avoid cross contamination or what businesses can do around this?

James: When you are a food manufacturing business or a catering business, you need to control the potential for cross contamination with food allergens. This is a big risk for people who are allergic or intolerant to foods.

Some questions to ask yourself: Did you get all the information from your suppliers? Did they add precautionary allergy labeling, for instance, to any of their products? And if so, was this following a proper risk assessment? Ask them, how do you store your raw ingredients in house? Do you use lidded containers, for instance? Are these stored so that there's a low chance that they could contaminate other ingredients? Putting the flours, for instance, on the bottom shelf instead of the top shelf where they can fall down on other food ingredients.

Do you or could you use colour coding for utensils or storage containers for use with allergens and preparing allergen-free dishes? We're referring here to things like gluten-free toasters or indeed the use of toaster bags. If you're a manufacturer, can you schedule your production so that one line doesn't contaminate another?

Cleaning, of course, is vitally important. Giving a pot or a wok a quick rinse with hot water will not remove allergens, that, unlike bacteria, are not destroyed by cooking or baking. You need to use detergent, hot water, and a good bit of elbow grease to properly clean utensils and pots and ensure they are allergen-free.

If you are an manufacturer, how do you manage rework? Does this increase the risk of cross contamination, for instance? Are your staff fully trained and aware of the importance of controlling food allergens? Is this training reinforced periodically? Remember, if you are unsure of the risk of cross contamination, you should tell the customer and let them decide on whether or not to purchase a particular menu item.

Linda: So if food businesses want more information and guidance to help them get it right in relation to food allergens, where can they go to find that kind of resource?

James: Well safefood have a number of freely available resources that food businesses can use to train their staff and help them accommodate their food allergic, Coeliac, and food intolerant customers. These are available on the safefood website. So do a search for safefood.

By the way, this includes resources that help caterers address the whole issue of gluten free. To assist food businesses in keeping track of their allergenic ingredients, check out MenuCal which is freely available on both the websites of the Food Safety Authority of Ireland and the Food Standards Agency in Northern Ireland.

Linda: That's great, I think on that note we'll leave it there. Thank you very much to James McIntosh for that very comprehensive overview of allergens. I'm Linda Gordon and thank you for joining us today.

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Until the next time, goodbye and take care.