FSA UK – Survey on allergen advisory labeling

The survey examined the type of allergen advisory labelling present on pre-packed processed foods sold in the UK, and aimed to quantify the level of allergens resulting from cross-contamination and establish whether the type of advisory labelling used related to the level of allergen present.

The current regulatory framework within the European Union mandates the declaration of 14 allergens as constituent ingredients (i.e. peanuts, nuts, soybeans, mustard, eggs, lupin, milk, fish, cereals containing gluten, sesame, celery, sulphur dioxide, molluscs and crustaceans) in pre-packed foods. This legislation does not cover unintentional cross-contamination with allergens or the resultant use of advisory labelling.

The FSA introduced ‘best practice’ guidance on managing food allergens in 2006 to assist the food industry in the use of advisory labelling. However, due to the lack of standardisation in allergen risk assessment methodology and inconsistencies in allergen management practices, the application of advisory labelling varies in the way it is presented to consumers.

These variations have led some allergic consumers to believe that different types of advisory statements convey different levels of risk (i.e. ‘made in a factory that also handles X allergen’, versus ‘made on a line that also handles X’ allergen).

It was anticipated that the results of this survey will help to inform the development of proportionate risk based allergen management thresholds (known as action levels). It was envisaged that action levels will be used by the food industry as well as by regulatory and enforcement bodies to inform decisions about allergen management, and enable the appropriate use of allergen advisory statements, such as ‘not suitable for those with X allergy’ on pre-packed foods. Furthermore, it was anticipated that action levels will help food businesses make evidence-based decisions on the use of factual statements about whether or not a food is suitable for consumption by someone with a food allergy.

Five hundred and eight pre-packed processed foods were purchased in duplicate (two samples with identical batch/production codes giving a total of 1,016 products) from a range of retail outlets across the UK, including major and smaller national supermarkets as well as independent retailers. Products with allergen advisory statements and an equal number of comparable products without such statements were purchased.

Samples were tested for the unintentional presence and quantity of one or more of the following four major food allergens: milk, gluten, peanut and hazelnut. These allergens were chosen due to the large number of incidents the FSA received over the past few years and because of their importance to public health.

The survey examined the different types of advisory statements used on pre-packed foods and compared the use of these phrases to the levels of allergens present. It was anticipated this may help to establish whether the use of certain advisory statements are linked to the level of allergen present and indicate whether different types of statements convey different levels of risk to the consumer. In addition, the survey examined whether the suggested advisory labelling statements set out in the FSA’s Best Practice Guidance were being used by industry.

The snapshot nature of this survey and sampling methodology means that it may not be representative of the entire UK retail market; it is therefore difficult to extrapolate findings to the UK retail market as a whole. The main findings are as follows:

Undeclared allergen cross-contamination in the UK is lower than previously found in studies in other countries, notably Ireland and the USA.

The percentage of samples with detectable allergen (both with and without advisory labelling) and where that allergen was not present as an intentional ingredient, were as follows: gluten – 6.1% (33/542); milk – 8.2% (39/474); hazelnut – 2.9% (29/988); peanut – 0.21% (2/950).

The percentage of samples with detectable allergen, where that allergen was not present as an intentional ingredient and which did not carry an advisory label were as follows: gluten 3.3% (18/542); milk – 2.1% (10/474); hazelnut – 0% (0/988); peanut – 0% (0/950).

The percentage of samples in which no allergen was detected but carried an advisory label were as follows: gluten – 19% (97/509); milk – 18% (77/435); hazelnut – 44% (427/959); and peanut – 45% (430/948).

The wording of the advisory label did not reflect the level of cross contamination found (for any of the four allergens across any product category).

A wide variety of different statements were used across the product categories. The most frequently used advisory label was ‘may contain traces’ (38% (418/1106)). The second most frequently used was ‘may contain’ (20.6% (228/1106)).

FSA guidance recommends the use of ‘may contain X’ or ‘not suitable for someone with X allergy’. These two statements were found on 20.6% and 7.2% (80/1106) of products, respectively.

The survey is available here.

(Source: FSA website)

FVO Reports – Pesticide controls in UK? Not the best probably…

From the following report of the Food Veterinary Office (here you can read the executive summary) seems that United Kingdoms not doing so well about pesticides controls. Click here to read and download the full report.

The report describes the outcome of a Food and Veterinary Office (FVO) audit in the United Kingdom, carried out between 14 to 22 October 2013, under the provisions of Regulation (EC) No 882/2004 on official food and feed controls and Regulation (EC) No 1107/2009 on the placing of plant protection products on the market.

The objective of the audit was to evaluate the system of authorisation and the controls on the marketing and use of pesticides. A comprehensive system is in place in the UK for the authorisation of pesticides. Authorisation procedures are fully in line with EU requirements. However, the deadlines prescribed in EU legislation for authorisation and re-registration of pesticides are not met in about ten percent of the cases.

There are no systematic, risk-based controls on the marketing of pesticides. Compliance of pesticides with requirements of the authorisation, including labels are not checked at distributors. Instead, investigations are initiated only in response to complaints or information on potential non-compliances obtained from external sources. There are certain initiatives for coordinated controls by the relevant authorities in order to combat illegal pesticides.

Although the formulation laboratory has the necessary capability for comprehensive controls, the number of pesticide samples analysed and the method of sampling does not provide adequate assurance for detection of non-compliances. Although there are regular risk based controls on the use of pesticides at growers, in the framework of the cross compliance controls, the system does not cover about 10-15% of professional users in the UK, including numerous large and medium size fruit and vegetable farms.

Different central competent authorities (CAs) are responsible for official controls in the different countries of the UK. The central competent authorities have no information about the controls carried out by the local authorities. Therefore the UK does not provide an annual report to the Commission on the scope and results of official controls on the marketing and use of pesticides, as required by EU legislation.

There are detailed procedures in place for enforcement in the case of non-compliances, including prosecution and the application of penalties. However, the CAs do not always take appropriate actions to ensure that the operator remedies the situation. Sanctions are not always effective, proportionate and dissuasive.

The report makes a number of recommendations to the CAs, aimed at rectifying the shortcomings identified and enhancing the implementation of control measures.