Accurate allergy labelling is a pertinent issue for food manufacturers. Food Standards Australia and New Zealand (FSANZ) states that between four and six percent of children and one to two percent of adults suffer from serious food allergies.
Mandatory declarations regarding the presence of allergenic ingredients were introduced in Australia and New Zealand in 2002, with rigorous declaration requirements considered to be the most appropriate risk management option.
However, precautionary statements such as ‘may contain traces of…’ or ‘processed on the same equipment as food that contains…’ are not regulated in the Australia New Zealand Food Standards Code (the Code) and have been criticised by key allergen groups and academics.
A recent study published in the Medical Journal of Australia questioned the wording of a host of allergy declarations, concluding that ambiguous terms such as ‘may contain traces of’ can lead to varied levels of caution by consumers – regardless of the actual risk.
The study was a collaboration between the Victoria University, the Murdoch Children’s Research Institute and the Royal Children’s Hospital, and focused on whether the wording of allergen labels influenced purchasing decisions.
The study surveyed 250 parents of children with a history of anaphylaxis and found that 65 percent of the sample ignored warning labels stating that the food was ‘made in the same factory’ as allergenic foods and 22 percent of respondents ignored labels warning that allergens ‘may be present’ in the product.
Lead author of the study, Victoria University PhD Giovanni Zurzolo, said that results of the study were quite alarming and highlighted inadequacies in food labelling legislation.
“Although these warnings may actually represent the same or similar levels of risk, consumers perceived different risks based on the different wording of precautionary labels,” said Zurzolo.
“Policies that promote greater clarity and consistent use of precautionary statements may help to deal with this complacency.
So what is the value of voluntary precautionary statements? Should they be regulated to ensure transparency for both consumers and manufacturers? How does different wording affect purchase decisions and what are food manufacturers and industry stakeholders doing to combat ambiguous allergen labelling practices?
Allergies: a threat to your brand and your buyers
A vast number of foods threaten to cause severe allergic reactions including anaphylaxis.
According to FSANZ, the majority of food allergies are caused by the consumption of peanuts, tree nuts, milk, eggs, sesame seeds, fish and shellfish, soy, wheat and other sources of gluten.
Each of these ingredients must be declared no matter how much of the ingredient is actually present in the food, under Standard 1.2.3 of the Food Standards Code.
In July this year, Australian bakery, Sunfield, was fined $48,000 and $21,000 in legal costs for failing to declare nut and egg contents in its cakes, and last year pre-mix cake company Duncan Hines was in hot water over undeclared tree nuts, resulting in nationwide product recalls.
FSANZ, along with key allergy consumer groups, is currently working with industry to make precautionary labels more helpful and transparent for allergy sufferers – this includes the potential inclusion of precautionary labelling as part of a broader review of the Regulatory Management of Food Allergens (2010).
FSANZ together with government, industry and consumer groups, launched the Food Allergy Portal in May this year. The portal was developed by the Allergen Collaboration, which was established by FSANZ in late 2011 in an effort to strengthen engagement amongst key stakeholders involved in food allergen management.
"Consumers with food allergies continue to benefit from the food manufacturing industry’s long and successful track-record of working collaboratively to ensure safer food choices,” Australian Food and Grocery Council (AFGC) CEO, Gary Dawson, said.
"This new allergy portal is an important addition to the information and tools already available in promoting awareness about food allergies and how to manage them. The portal also allows new best practice resources to be promoted, as well as filling gaps in education materials," said Dawson.
In addition to the Allergy Portal, the AFGC established the Allergen Bureau in 2005 to assist the food industry, consumers and the wider community to understand food allergen issues and provide consistency and transparency in labelling requirements.
The Allergen Bureau launched a new initiative, in conjunction with Anaphalaxis Australia named VITAL – Voluntary Incidental Trace Allergen Labelling.
VITAL was designed to assist industry to better communicate the presence of non-intentional allergens and acts as a full risk management approach designed to minimise the potential impact of incidental allergens including everything from ingredient management to factory design.
VITAL uses world-leading assessment tools to manage incidental allergen risks, and if labelling is required, provides a single statement to communicate that risk: “MAY BE PRESENT: (list of allergens). This single statement was developed in conjunction with allergy sufferers and was specifically intended to avoid confusion arising from ambiguous statements such as ‘made in the same factory.’
While Zurzolo believes that VITAL is a step in the right direction, he says the system has its limitations.
“We have previously reported that since its establishment, uptake has been low”, Zurzolo told Food magazine.
“A limitation of the VITAL process is that it underpins another precautionary statement, the ‘may be present’ statement, which is similar to the other precautionary statements.”
Zurzolo also adds that there is no information on food products alerting the consumer that products bearing this statement have undergone a different risk assessment.
“Other countries such as Japan and Switzerland have banned the use of precautionary statements on food products. Instead, they use established threshold levels as a basis for recommendation to determine if an allergen is labelled in the ingredients list or not,” he says.
“In the current Australian situation where there is no law forbidding precautionary statements, VITAL is a step in the right direction. In order to make these statements more transparent, consumers need to be made aware that products that bear the VITAL statement have undergone a different risk assessment and may be potentially safer for them to consume.
“We urgently require all manufacturers to implement VITAL into their risk assessment, and for VITAL to label their food products so that any risk is clear to the allergic consumer.”
You can never be too careful
Keeping up to date with regulatory changes and voluntary agreements can be a challenging matter for food manufacturers especially for SMEs.
Adelaide based chocolate manufacturer Haigh’s chocolates has taken precautionary statements to the new heights by listing a particular allergen, milk, as an ingredient.
A few years ago, the chocolate manufacturer expanded to two manufacturing plants and while restructuring, they temporarily combined the milk chocolate and dark chocolate manufacturing lines.
A number of the dark chocolate lines do not contain milk as an ingredient, however due to the nature of the new manufacturing line, the risk of milk contamination increased, and varying trace levels of milk were recorded. From this, Haigh’s decided to declare milk as an ingredient in order to eliminate any potential risk for allergen sufferers.
Haigh’s has now completed the upgrade and moved back to separate manufacturing lines for the milk and dark chocolate products which will avoid the risk of milk contamination and therefore labelling will be readjusted over the next 6 – 12 months.
To add to the company’s commitment towards food safety, Haigh’s will also be implementing a new initiative aimed at promoting transparency within allergen labelling in-store. Labelling will also be changed on all of Haigh’s products to promote transparency by listing all allergens under the ingredients list.
Maintaining best practice in allergy labelling
In order to keep abreast of best practice in allergen management, food manufacturers need to implement effective risk management programs.
FSANZ states that food manufacturers are responsible for managing the unintentional presence of food allergens. Keeping up with voluntary standards and changes in legislation may be a challenge for today’s manufacturers (who already have an abundance of red tape to deal with), but ignorance or complacency are no excuse for non-compliance.
The key recommendations that the FSANZ website lists for those food manufacturers determined to be proactive in allergen labelling are:
- Implement an effective allergen management plan
- Train staff in food allergen risks, management and communication
- Provide clear and accurate information on the allergen status of your product
When it comes to allergen labelling, it pays to be transparent. The vaguely specific precautionary statements that the industry has adopted up until now won’t cut it for much longer.
Who knows whether or not the government will legislate precautionary labelling? But regardless of the legal requirements, food manufacturers are highly encouraged to implement VITAL and be vigilant with their allergen declarations to ensure that any and all risks are clearly conveyed to the end-user.
ys to be transparent. The vaguely specific precautionary statements that the industry has adopted up until now won’t cut it for much longer.
Who knows whether or not the government will legislate precautionary labelling? But regardless of the legal requirements, food manufacturers are highly encouraged to implement VITAL and be vigilant with their allergen declarations to ensure that any and all risks are clearly conveyed to the end-user.