The injudicious use of 'may contain' warnings and the proliferation of their usage has resulted in the creation of yet another hazard for the allergy sufferer, writes Food Assist's Ron Cossen.
Today, no one questions the importance of labelling food products in a way which ensures that those suffering from a food allergy are warned about the possible presence of allergens. However, it wasn’t always like that. Until the late 1980's, products could contain peanuts without any mention of peanuts on the label; because, allergens could be hidden in so called ‘compound ingredients’. Simply, if compound ingredients were present in quantities less than five percent, allergens could be hidden and consumers none the wiser.
In the mid 1980’s, it was clear that regulators, the food and beverage industry and the medical profession were disinterested and unaware of the needs of allergy sufferers.
In 1991, regulators took their first steps toward recognising the predicament of allergy sufferers. In that year, the Australian Food Standards Code was amended to read “the presence of peanuts shall always be declared”.
For those allergic to other food ingredients, the wait would be a number of years before they were accorded the same treatment.
As we are aware, allergens can be inadvertently introduced through ingredient supply or through processing. About 15 years ago, when manufacturers voluntarily introduced the statement “may contain nuts” (or "may contain xxxx") on labels for products that were at risk of cross contamination, it appeared to be a good idea.
For example, a processing line that has been producing chocolate coated peanuts is cleaned and then commences production of chocolate coated sultanas. In this situation, one can appreciate that there is a possibility of traces of peanut material being present in packs of chocolate coated sultanas.
However, unfortunately, the injudicious use of this warning and the proliferation of its usage has resulted in the creation of yet another hazard for the allergy sufferer.
We have reached the situation where more than 50 percent of foods in the supermarket have “may contain” (or similar) warning statements.
Food Standards Australia New Zealand conducted a survey to assess the value of the words "may contain" and reported that 54 percent of allergy sufferers found the statement to be not very useful.
Further, many respondents added that they feel:
- the "may contain" statement is overused, and
- manufacturers are just covering themselves legally.
The diversity and vagueness of these “may contain” statements has created a situation where many allergy sufferers disregard them. Add to that the voluntary nature of such statements and we could be confronted with the following situation.
If “Smith's” Biscuits includes a statement on the label “may contain traces of nuts” and Brown’s Biscuits do not have a statement regarding possible nut contamination, which is safer for a person who has a nut allergy? Brown’s? Of course, it is? Not necessarily.
Consider the excellent work of the Allergen Bureau and its initiative called VITAL, which stands for Voluntary Incidental Trace Allergen Labelling.
The Allergen Bureau was established in 2005 with the objective of sharing experience within the food industry on the management of food allergens. The aim is to ensure that consumers receive relevant, consistent and easy-to-understand information on food allergens.
As we are aware, food allergens may be present in a food due to unintentional cross-contact – even sometimes under conditions of good manufacturing practice.
VITAL assesses likely sources of cross contact, evaluates the amount present and reviews the ability to reduce the presence of allergens.
The Allergen Bureau has established a Scientific Expert Panel that reviews and monitors food allergen thresholds. This expert panel consists of world leading scientists specialising in food allergy, allergen management and risk assessment.
The threshold is the amount of allergen required to provoke a reaction.
The Allergen Bureau's recently released VITAL 2.0, replacing the original VITAL guide, addresses threshold levels. It's also stepped into the world of "May contain" labelling.
The guidelines that the bureau has released are as follows:
- The precautionary labelling statement [‘May be present’] is used only when the cross contact allergen is at Action Level 2 on the VITAL action level grid.
- The precautionary statement is declared as ‘May be present: xxx’, where ‘xxx’ lists each of the cross contact allergens present at VITAL Action Level 2.
- The statement [‘May be present’] is placed below the summary statement on a separate line in bold print.
- The allergen cross contact statement text must be declared using the same font size as the ingredient list information or at the minimum print size of 1.5mm.
It is important to note that the core message of VITAL 2.0 is to reduce cross contact allergens wherever possible and the core focus is on meaningful and consistent precautionary labelling.
The initiative of VITAL has been recognised internationally and other countries are now seeking to adopt the program. The Allergen Bureau is currently responding to requests to endorse VITAL trainers in European countries and South Africa, with interest being shown by America and countries in Asia. Approximately half the traffic to the VITAL website is from outside of Australia and New Zealand.
The VITAL initiative is excellent. However, "V" stands for Voluntary.
We have made progress over the years. Certainly, with regard to the presence of allergenic ingredients in labelled food products. However, there is more work to be done.
Ronald Cossen, Principal of Food Assist, a firm that provides consulting and recruitment services to the food manufacturing industry. Cossen will be presenting seminars on food labelling at next week’s 14th Annual Food Regulations & Labelling Standards Conference, at the Sydney Harbour Marriott Hotel.