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An estimated two million people in the UK have a diagnosed food allergy. Symptoms of an allergic reaction can range from mild discomfort to life-threatening anaphylactic shock. To limit the possibility of someone with an allergy unknowingly coming into contact with an allergen, food production companies need to ensure that they are working safely, in accordance with both the law and best practice.
Understanding food allergens
People can be allergic to a range of different ingredients and foods; however, there are 14 allergens that the law requires food businesses must declare on their menus or food labels in the UK. It is important that businesses communicate clearly to their customers if any of these allergens are, or may be, present in their items.
The 14 allergens are:
- Cereals that contain gluten (including wheat, barley and oats)
- Crustaceans (including prawns and crabs)
- Molluscs (including mussels and oysters)
- Sulphur dioxide/sulphites (if they are at a higher concentration than 10 parts per million)
- Tree nuts (including hazelnuts, pistachios, cashews and walnuts)
These allergens apply to not only the finished product but also any ingredients, manufacturing or processing methods used. This is why you may see a product that is labelled vegan contain a warning label that it may contain milk – this is due to the fact that trace amounts of milk could be present due to production and manufacturing methods.
Of the approximately two million people in the UK who live with a diagnosed food allergy, around 600,000 of these have coeliac disease. Coeliac disease is a lifelong, autoimmune condition that is caused by a reaction to the allergen gluten. There is a law that covers products that are labelled as gluten-free. When this label is present on packaging it means that the foods contain 20 parts per million (ppm) or less of gluten, making it suitable for a gluten-free diet.
Allergen management in food production involves:
- Identifying allergens
- Testing and checking for allergens
- Managing allergens
- Understanding the law around allergens
- Labelling food correctly
- Educating and training all food handlers and food workers
Places of food production need to think about their own policies and procedures as well as those of suppliers. What happens in the supply chains before a product reaches a customer may affect the safety of a finished product.
All food businesses have a responsibility to provide food that is safe for consumption. This means food that is prepared in a hygienic and hazard-free environment as well as providing information about allergens.
Food law states that customers must be notified of the 14 allergens on prepacked foods, as well as in restaurants and on buffets. On packaging you will see that allergens are in bold to make them easier to identify. Many restaurants now include information about allergens on their menus and will have an allergy sheet available on request for both customers and staff to consult.
Legislation anyone overseeing the manufacture or production of food should be aware of includes:
If you manufacture pre-packed food, you should be familiar with:
- EU Food Information for Consumers Regulation EU FIC
Your food is pre-packed if:
- It is either fully or partly enclosed by the packaging
- It cannot be altered without opening or changing the packaging
- It is ready for sale
Pre-packed food needs an ingredients list and allergens should be highlighted (usually using bold text, underlining or in a contrasting colour). Labels can also contain additional advice for consumers such as ‘Allergen advice: for allergens see ingredients listed in bold’.
In 2021, new legislation was introduced known as Natasha’s Law. This law was named after Natasha Ednan-Laperouse who tragically died of anaphylaxis after eating a sandwich that she was unaware contained sesame seeds, to which she was highly allergic. Natasha’s Law means that all pre-packaged food for direct sale (PPDS) must be labelled with:
- Name of the food
- Full ingredients list
- Allergens clearly labelled and highlighted on the packaging
Natasha’s Law exists to protect consumers who have severe allergies, and the roll-out of this legislation aimed to save lives.
Examples of PPDS foods include:
- Pre-packed sandwiches that are made packaged up prior to a customer ordering them
- Burgers left under a hot lamp that cannot be customised or altered without removing the packaging
- PPDS foods (sandwiches, cakes etc) provided in schools, hospitals and care homes
- Packaged foods that an operator moves to sell onto a different site (such as at a mobile catering van)
Vendors and producers of food items that are not PPDS are still required to be able to provide allergen information; this may be done orally or visually, such as on an allergen sheet.
Allergen risk assessment
An up-to-date allergen risk assessment is key in preventing an instance of allergen contamination. Risk assessments are also useful tools for staff to have access to. You should complete risk assessments for each area of the business that handles food and allergens.
Before you start your risk assessment, you may find it helpful to complete an allergen checklist. This can help you to identify where allergens may be present.
Procedure for an allergen risk assessment:
- Identify hazards. To complete a risk assessment, you first need to identify any hazards that are present.
- Identify risks. Who may be at risk due to the hazards and how? This will be consumers who have allergies.
- Current procedures. What procedures are already in place? It may be that you have a dedicated area for handling gluten-free items or that any equipment that touches milk products is colour coded.
- Further action. What needs to be added to the current procedures or changed to mitigate risk?
Your risk assessment should be as detailed as possible and make note of what is to be actioned specifically and who is responsible for overseeing it.
A key component that you use in the factory has changed recipe and now contains milk. You identify this as a hazard as you know milk is one of the 14 allergens.
This means that anyone with an allergy to milk is potentially at risk if you continue to use this item in your manufacturing processes.
You already have procedures in place to keep a record of products with allergens in and store them separately from allergen-free products. However, this does not remove the risk in this example.
Further action may be to change the recipe of your product now a component contains milk or to change your labelling to alert consumers. Furthermore, you would record that staff should always be checking for allergens on labels and be aware that the ingredients in products can change.
Having procedures in place to manage and mitigate risks is key in food production. As a business you should:
- Know the 14 allergens, where they may be present in your business and have procedures in place to manage them.
- Work with regulatory bodies to ensure 100% compliance.
- Take responsibility.
- Have a detailed Hazard Analysis and Critical Control Point (HAACP) plan in place as a preventative measure to control potential hazards. This is required by law.
- Protect your business from legal action and fines by acting in accordance with your HAACP plan, up-to-date food law and best health and safety practice at all times.
- Communicate effectively with suppliers, performing checks on ingredients, methods, incoming goods and labels.
- Make sure effective systems are in place. Review and change them as needed.
- Utilise software and other technology to help you search databases, check lists and communicate with others further down the production/distribution line about allergen information, hazards or incidents.
You may also need to conduct a risk assessment for allergen cross-contamination. The main purpose of this is to decide the likelihood that an allergen may cause unintentional cross-contamination via the supply chain; this means thinking about the journey of raw ingredients right through to them forming a finished product.
Some manufacturers choose to put additional information on labels to warn of unintentional allergens. This is when allergens enter products by accident through manufacturing and production processes. This warning is known as precautionary allergen labelling (PAL).
PAL is best only once a risk assessment is complete which finds that risks cannot be otherwise mitigated, rather than as a substitute for upholding best practice within health and safety and hazard awareness.
Overusing PAL can seriously impact on the choice of items available to consumers. The Food Standards Agency (FSA) instead encourage food businesses to look at ways they can change their methods or make different supply-chain decisions around allergens, rather than use a precautionary ‘catch all’ label. A PAL warning may look like this:
- May contain nuts
- Not suitable for those with a milk allergy
- Packaged in an environment that also handles wheat, gluten and soya
Having a system in place to monitor and test food, as well as respond to incidents, trace ingredients and manage risks, significantly reduces the likelihood of an allergen-related incident occurring.
If you want to be able to produce and label an item as free from an allergen, such as wheat-free bread or dairy-free chocolate, this is subject to strict controls and additional risk assessments.
Allergen control measures
- Use separate equipment and utensils to handle products that contain allergens
- Have a regular and robust cleaning schedule
- Ensure that there is adequate storage and that products containing allergens are in dedicated areas
- Ensure that your kitchen or work area is kept clean, tidy and well organised
- Ensure that the correct labels and placed on food items
- Employees who handle, serve or produce food that contains allergens should undergo regular training
- New employees should always complete an allergen awareness course when they join a business, even if they have previously completed one elsewhere
- There should be clear signs up in the workplace reminding staff of allergens and the law
- Lead from the top down; employers should show a good example to their employees with emphasis on accountability, good housekeeping and continuous learning
- Labelling needs to be clear and consistent
- Any of the 14 allergens present need to be visible in bold so that they can be identified more easily
- Consider whether a product requires additional may contain information under the ingredients list
- Precautionary allergen labels should only be used if other mitigating methods are unavailable and should not be misleading (for example a PAL cannot say may contain allergens)
Traceability and recall plans
Sometimes, despite efforts to keep food safe, communication breaks down, or an incident occurs due to human error or the accidental introduction of an allergen, and a product needs to be withdrawn (removed from the supply chain) or recalled (removed from the supply chain and an additional warning put out to consumers to either return or destroy items). This would be done to protect the public from a product that is unfit, such as not labelled with the correct allergen warnings.
Food businesses are required to be able to identify their:
- Suppliers of food
- Food-producing animals
- Any other substance that is likely to be incorporated into food
They should also be able to identify the businesses that they supply and be able to provide this information to the authorities if required. This means they need to have systems in place to trace ingredients and understand their part in the supply chain. This is known as traceability.
The purpose of traceability is to assist with the recall of any items that do not comply with The Food Safety Act. This would include food that is not safe for human consumption due to contaminants or food that is incorrectly labelled in a way that is misleading or has allergens that are incorrectly labelled.
The Food Standards Agency or your local council authority should be contacted in the event of a product needing to be recalled and they can assist with the procedure. A withdrawal plan comes into effect when:
- Food is considered by the operator to be unsafe (due to an event at any stage in the supply chain)
- The food is out of the immediate control of the initial operator (meaning it has already been distributed or shipped and they no longer have possession or control of the items)
To help you with your traceability and recall plan:
- Maintain clear record-keeping
- Don’t cut corners
- Only deal with reputable suppliers
- Understand your supply chain
- Make use of technology to streamline and simplify systems
- Have a plan in place before an incident occurs; be proactive rather than reactive
- Know what traceability means and how to make it work within your business
Be sure that you have an effective and clear plan in place in the event of a product needing to be recalled due to allergen-related issues and that anyone involved understands their roles and responsibilities. Make sure that you also know how to contact relevant authorities such as the FSA.
It is easier than ever to get information out there fast to consumers and other businesses by using social media and email; however, you need to know who to target and what the issue is to avoid causing unnecessary panic or product wastage.
By having these plans in place, you can empower consumers to make safer, more informed decisions and reduce the risk of an allergic reaction happening.
The UK has some of the highest prevalence of allergies in the world, with over 20% of the population suffering some form of allergic disorder (M. L. Levy 2004), and according to Food Matters, over half of adult sufferers have more than one allergy.
To help people with severe allergies make safe and sensible choices around food, it is vital that all food businesses (including producers, vendors, restaurants and cafes) are allergen aware and work in a way that is compliant with food law, allergen labelling and best food-safety practice.