Selection of common foods related to allergies

Asking our network about their food allergen cross-contact concerns

21 September 2023 | Helen Arrowsmith, Regulatory Affairs Manager and Allergen Specialist and Christopher James, Safety and Quality Specialist - Allergens

When asked in our recent poll, ‘What do you consider as the biggest challenge in ensuring the safety of food for those with food hypersensitivities?’, which was answered by over 100 food and drink industry professionals, almost half of respondents chose cross-contact from the list of options.

The results were:

What do you consider as the biggest challenge in ensuring the safety of food for those with food hypersensitivities?

Cross-contact – 48%
Labelling – 22%
Supply chain information – 26%
Testing – 4%

Taken overall, the results from all of the polls seem to suggest that it is the ‘unknown’ that is the main driver of concerns around food allergen cross-contact

We conducted some follow up polls that shed light on the issue of cross-contact in a little more detail. Taken overall, the results from all of the polls seem to suggest that it is the ‘unknown’ that is the main driver of concerns around food allergen cross-contact.

It seems that limitations in the provision of information about food allergen cross-contact risks throughout the food chain (i.e. supply chain information, voted at 26%) are a key driver of the concerns that end producers have (alongside managing cross-contact risks within their own facilities) about ensuring the safety of their food products for those with food hypersensitivities. Combined, concerns about allergen cross-contact and provision of supply chain information regarding food allergens make up 74% of the votes.

The subsequent poll questions and answers were:

What do you consider to be the biggest challenge in managing food allergens and preventing cross-contact?

Supply chain information – 35%
Segregation – 25%
Cleaning – 23%
Equipment design – 17%

As with the first poll, supply chain information scores highly here. Having said that, the results of around 20-30% for all answer options are fairly evenly split. Participants are likely concerned about the control of food allergen cross-contact within their own operations (through means such as segregation, cleaning and good hygienic design of equipment) as well as in the operations of their raw material producers and suppliers earlier in the food chain.

What do you consider to be the biggest food allergen cross-contact risk affecting your business’s products?

Processing – 59%
Agricultural cross-contact – 20%
Food fraud – 18%
Transport – 4%

The high result for processing further reinforces the message that may be gleaned from the previous poll – namely that processing (whosever operation it takes place within) presents the risk of food allergen cross-contact. It is likely that food and drink industry professionals feel much more able to manage this within their own operations than within those that are outside of their direct control.

The low result for transport here could be explained by participants in the food chain who are receiving well controlled and already packaged products. Food allergen cross-contact can, though, occur at many points throughout transportation, including dispatch, logistics and receipt of materials. Bulk materials in tankers or containers could, for example, be subject to food allergen cross-contact if robust controls are not effectively implemented in the supply chain.

Food product nutrition label on packaging

In which of these areas of food allergen labelling would you most benefit from support?

Quantitative risk assessment – 43%
Precautionary information – 39%
Global markets – 13%
Free-from claims – 6%

The results of this final poll emphasise the importance of the provision of information throughout the food chain, since such information is needed in order to make an informed decision regarding precautionary allergen labelling (PAL) of finished end products.

A rapidly evolving way of deciding whether PAL is needed for final products is quantitative risk assessment (QRA), which uses clinically derived reference doses (an amount of total protein from an allergenic food in milligrams (mg)) to calculate action levels for reference amounts of the particular product (the units for action levels are mg total protein of the allergenic foodstuff/kg of the food product). If analytical results or calculations are above the action level this suggests that PAL is needed.

It is important to remember that the decision whether to apply PAL should not be based on analytical test results and/or QRA alone; rather testing should be used in combination with calculations and holistic information gathered to inform the decision-making process.

Currently, there is no steer from regulatory authorities at harmonised EU level or in the UK on the use of QRA to decide whether PAL is needed. It is therefore a business decision for each food business operator (FBO) in these jurisdictions to decide whether to use QRA.

For information on QRA please see our blog on developments in precautionary allergen labelling and information.

It is crucial that there is a transparent chain of communication throughout the food chain.

Where FBOs decide to use QRA, information on the concentration and protein content of cross-contact of food allergens within supplied ingredients would be needed to facilitate effective QRA. This, however, represents a step change in the provision of information throughout the food chain, which may take time to achieve. It is recommended that in the meantime a risk-based approach is taken, consisting initially of the collection of basic information (i.e. is there potential cross-contact?, what does the cross-contact consist of?, why and at what levels?).

It is clear that the provision of accurate information on food allergen cross-contact throughout the food chain is imperative to ensure that correct information is provided to consumers with food hypersensitivities about the safety of the food they consume.

We can help you to ensure food safety

Food allergen cross-contact can occur at every stage of the food chain, from ‘farm to fork’. Dealing with this can be challenging – but we are here to help.

If you need any information or support, get in touch. We provide a range of services to support your food allergen management needs, including; food allergen training courses, testing, and practical support with cleaning validation, hygienic design, food safety management systems, labelling and legislation.

If you would like a full label review from our global regulatory experts to check the compliance of your products across UK/EU and Global markets, get in touch with the Regulatory Affairs team (regulatoryadvice@campdenbri.co.uk).

Alternatively, for more information on the topic areas above, and the many other necessary considerations when producing legally compliant products, check out our training courses.

About Helen Arrowsmith

Helen is a Regulatory Affairs Manager and Allergen Specialist who uses her knowledge and expertise to provide advice, training and consultancy on all aspects of UK and harmonised EU legislation, as well as food allergen analysis, cleaning validation and management. Helen presents on scheduled and tailored training courses on food law and food allergens, and oversees the production of our Food Law Alert.

After her PhD, Helen joined Campden BRI in 2004 when she spent a year as Technical Support Officer in the Food Composition Section. The next nine years were spent in the Biochemistry Section, where Helen managed the provision of technical contract services in the area of food allergen detection, provided interpretation of testing results, consultancy, research and advice on food allergen testing.

In 2014, Helen moved to our Regulatory team where she has gained comprehensive understanding and experience of food law, not just relating to food allergens.

Helen has managed various research projects; in 2023 she supervised and contributed to a Review of the literature and guidance on food allergen cleaning for the Food Standards Agency . Helen has also co-authored two guidance documents for the food industry on ‘Validation of cleaning to remove food allergens’ (Campden BRI Guideline 59) and ‘Food allergens: practical risk analysis, testing and action levels’ (Campden BRI Guideline 71).

About Christopher James

Christopher James is a Safety, Quality and Allergens Specialist who uses his knowledge and expertise to manage consultancy and research projects, tutor courses in all areas of food safety and quality management and provide specialist support to clients with substances causing food hypersensitivity (including food allergens). He joined the Global Safety and Quality team at Campden BRI in 2019, after roles in various public health and food organisations, bringing his knowledge of nutrition, health, dietary conditions (including food hypersensitivity), food safety, quality and science.

Christopher has authored peer-reviewed articles, book chapters, guidance and reports on current scientific and industry topics, including collaborating with BRCGS in the development of guidance on ‘Effective Allergen Management’. He graduated from Coventry University with a BSc (Hons) in Nutrition Studies, is a Registered Nutritionist (RNutr) and a Member of the Institute of Food Science and Technology (MIFST). Alongside his current role, he is undertaking a PhD at the University of Nottingham conducting research into current and emergent allergens in food production systems.