Optimising food allergen management – through risk management and risk communication

15 May 2024 | Helen Arrowsmith, Regulatory Affairs Manager & Allergen Specialist; Christopher James, Safety and Quality Specialist – Allergens; Marie-Anne Clarke, Team Manager – Allergens; Andrew Collins, Global Food Safety Lead

Our ‘Optimising food allergen management’ member-only event in late 2023 focussed on risk management and risk communication to ensure effective process controls for safe food.

Expert speakers covered the latest developments in managing food allergens and communicating information on their presence (either deliberate or unintended), including techniques used in other industries to visualise and better communicate risk, provision of information throughout the supply chain, and developments around precautionary allergen labelling and information.

The day was split into four themes:

1. The latest on food allergen quantitative risk assessment (QRA) and precautionary allergen labelling (PAL);
2. Updates on the Food Standards Agency work on food hypersensitivity;
3. Food allergen risk communication, and;
4. What happens when things go wrong.

This white paper is structured into these four key sections and summarises some of the key insights and updates shared during the event. The slides from the day are available to members for a limited time only.

We have further member events planned, for which the details and booking system can be found on seminars, conferences and events page.

1. Food allergen quantitative risk assessment (QRA) and precautionary allergen labelling (PAL)

The two talks in this session were delivered by our chair and vice-chair for the event, René Crevel of René Crevel Consulting and Neil Buck from General Mills, both of whom have been involved in recent developments relating to QRA and PAL.

The FAO/WHO expert consultation on risk assessment of food allergens

René Crevel spoke about the FAO/WHO expert consultation on risk assessment of food allergens in the context of making global allergen management fit for the 21st century. The audience heard about the ambitious tasks set by the Codex Alimentarius Commission and the series of meetings held to address those tasks, which took place between late 2020 and early 2023.

Five meeting reports based on the FAO/WHO expert consultation meetings have been published, ranging from reviewing and validating the Codex priority allergen list to reviewing and establishing threshold levels and precautionary allergen labelling. For more information, see our blog on the latest developments in precautionary allergen labelling and information.

Application of food allergen quantitative risk assessment

The application of action levels or reference doses to food allergen risk management and the communication of risk was discussed by Neil Buck, who talked about practical guidance on the application of food allergen quantitative risk assessment developed by ILSI Europe. The guidance covers methods and decision making on the implementation of allergen QRA across both upstream supply chains and in-house site operations. Also included is guidance on communication across the supply chain, management of operations, management of incidents, and core concepts to consider when conducting an allergen QRA. A link to the ILSI Europe guidance and further resources is available in our blog on the latest developments in precautionary allergen labelling and information.

Close up of hosepipe spraying water in factory

2. Updates on Food Standards Agency work on food hypersensitivity

The talks in this session were delivered by Ben Rayner from the Food Standards Agency (FSA) and Helen Arrowsmith of Campden BRI.

As part of their Food Hypersensitivity programme, the FSA have recently conducted work looking at how to improve the flow of information between consumers and food businesses. Under the same programme, they also commissioned a review on the food allergen cleaning literature and guidance available internationally.

The FSA’s work on food hypersensitivity

The FSA work around provision of information for when eating outside of the home identified a number of key needs for a safe and welcoming environment for people with food hypersensitivity, which were shared during this member event.

An FSA Board meeting has since taken place (December 2023), in which options to take the work forward were set out. A summary of the Board’s discussion on the provision of allergen information for consumers when eating out can be found on the FSA website.

With regards to PAL, the FSA updated their Allergen labelling technical guidance (updated August 2023).

Cleaning to remove food allergens

Cleaning to remove food allergens is part of a holistic food safety management system. The purpose is to control allergen cross-contact that can pose a risk to people with food hypersensitivity. Food businesses need to understand how effective their cleaning is at removing food allergens, in order to provide accurate information about food allergens that could be unintentionally present in their food.

The Food Standards Agency (FSA) commissioned a review, under their Food Hypersensitivity programme, on the food allergen cleaning literature and guidance available internationally. Campden BRI were selected to conduct the review, and the report will support the FSA in determining how best to take allergen cleaning guidance development forward, which will support the precautionary allergen labelling policy area. Helen Arrowsmith talked about the key findings from the work, which are also outlined in a case study, including key principles for allergen cleaning validation studies and future work.

3. Food allergen risk communication

The talks for this section were by Andrew Collins, Campden BRI and Nicola Smith, Partner at Squire Patton Boggs (UK) LLP. Respectively, they discussed effective food safety risk communication, and effective communication of food allergen information throughout the whole food supply chain.

Risk communication through the whole food supply chain is essential to enable people to make informed decisions that may affect their health, and managing food allergen information through the supply chain is of upmost importance. Allergen information and labelling must be accurate and there is a legal obligation on suppliers to provide information for prepacked and non-prepacked foods.

Food allergen risk management and risk communication

The ability to identify potential risks in order not just to overcome or offset, but also to communicate them in advance, is the core to successful allergen management. Risk management and communication tools can support the effective implementation of these concepts to help ensure safe food for consumers.

Key learnings can be taken from how other industries deal with hazards and risk, and how they communicate them to key stakeholders to improve understanding may help to manage food allergen risk. One approach called Bowtie can be applied in the management of allergens in the food industry.

Andrew Collins is a certified BowTie XP practitioner and spoke about BowTie methodology barrier risk-based thinking in the context of food allergen management. BowTie is a simple visual tool that makes qualitative communication of risk easy – helping you identify the threats, consequences and barriers to effectively manage food allergen hazards. View more on BowTie services.

Communication throughout the food supply chain

Since food allergen cross-contact can occur at every stage of the food chain, supply chain information is important for accurate allergen information.

Nicola Smith spoke about the legal obligation on suppliers to provide information for prepacked and non-prepacked foods. Even FBOs not supplying directly to the consumer or to mass caterers need to ensure that their customers (i.e. business to business) have sufficient information to allow them, where appropriate, to comply with relevant legislation with regards to allergen information.

It was also discussed that the Food and Drink Federation have issued guidance on allergen change management (September 2023), including guidance for the addition or removal of an allergen ingredient from a product, and decisions for the addition or removal of PAL. This includes considerations such as the reason for change, allergen risk assessment, label change review, front-of-pack alerts, product data on brand websites and other processes of informing customers, consumers and allergy organisations / charities.

4. What happens when things go wrong

This final session included two talks – one by Kate Lingley of DAC Beachcroft, and the second by Julia Johnson and Jen Upton, both from Instinctif Partners.

The first was a whistle stop tour of the regulatory criminal justice system's approach to prosecution and sentencing. The second talk was all about building resilience by robustly preparing for when things go wrong.

Prosecution in food safety matters

Kate Lingley spoke about the various pieces of UK and EU legislation, as well as codes of practice, that relate to food safety and food allergens. Examples were provided of both small and large businesses being prosecuted under this legislation.

Legislative provisions were discussed, including enforcement notices (such as hygiene improvement notices, Food Information Regulation improvement notices, and prohibition notices / orders) and criminal offences (such as ‘Offences due to act or default of a specified person’, ‘Gross Negligence Manslaughter’ and ‘Corporate Manslaughter’).

For Food Safety Offences, sentencing guidelines relate to the level of ‘harm’ and ‘culpability’. Organisations can face an unlimited fine (based on turnover), and individuals can face up to a band F fine (500-700% weekly income) or imprisonment (if there are sufficiently high levels of harm and culpability). For example, gross negligence manslaughter sentences can range from 1-18 years imprisonment depending on harm and culpability factors.

Why you should prepare to fail

Through a combination of case studies and best practice, Instinctif Partners shared the ‘Why’, ‘What’ and ‘How’ of building resilience in challenging environments by being prepared for when things inevitably do, at times, go wrong.

Being prepared means that, when things do go wrong, you can alert consumers more quickly, ensure clear and accurate recall information, make the right decisions, save yourself stress, protect your business’s reputation, and put yourself on track for a successful recovery.

It is important to be proactive, prioritise food allergen questions during any recipe / ingredient / supplier changes, and to highlight new allergens on-pack and via allergy organisations. To be prepared, you need to proactively identify and fill any ‘gaps’ in your recall process, build in strong communication, and make sure your procedures are properly embedded and tested.

Choose Campden BRI to help you optimise your food allergen management

Food allergen cross-contact may occur at any stage of the food chain, from ‘farm to fork’, so effective food allergen risk management and communication of accurate consumer information are essential for ensuring the safety of food for consumers with food hypersensitivity.

Dealing with this can be challenging – but we are here to help. With over 100 years of expertise, we are well-equipped to provide food and drink businesses with tailored, expert support in all areas of food allergen management, including; food safety management systems, risk management and communication, BowTie, food allergen testing, cleaning validation, hygienic design, legislation, food allergen labelling, PAL and QRA.

Our experts are well connected in the industry. Our experience extends beyond food hypersensitivity and encompasses a holistic understanding of global food safety, quality and regulatory requirements.

By working with us, you can make the most of our extensive offerings — whether that be support to your business, consultancy, legislative interpretation, research and development, or testing and training — to boost your level of control and confidence in producing safe food.

If you need any information or support, get in touch:

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.
For advice and further information on food allergen labelling and other legislation issues – regulatoryadvice@campdenbri.co.uk.
For technical information on preventing and monitoring food allergen cross-contact – support@campdenbri.co.uk.support@campdenbri.co.uk.

Alternatively, for more information on the topic areas above, and the many other necessary considerations when producing safe, 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.

About Marie-Anne Clarke

Marie-Anne is the lead contact for the Allergen Testing and Biochemistry Molecular Biology Teams. She uses her knowledge of biochemistry and molecular techniques, as well as experience working with food allergens and DNA techniques, to provide advice and consultancy on food allergen detection and species authenticity, as well as GMO detection.

Prior to joining Campden BRI, Marie-Anne obtained a BSc degree in Anatomical Science with her final year project on sequencing and characterising a novel gene in bovine cartilage. Marie-Anne joined Campden BRI in 2003, after two years in retail, initially as a molecular biology technician working on fish species identification, as well as conducting assays for detection of food allergens using ELISAs.

In 2014 Marie-Anne was appointed Team Leader of the Food Allergens Team, providing technical contract services in food allergen detection, interpretation of testing results and consultancy on testing for food allergens and cleaning validation. In 2020, Marie-Anne became manager of the Biochemistry Molecular Biology Team, who offer contract authenticity analysis services for fish and meat speciation and detection of GMOs.

About Andrew Collins

Andrew joined Campden BRI at the beginning of 2009. With over 30-years’ experience in a wide range of food businesses (including catering), his current role focuses on consultancy work with the holistic and practical application of food safety management including the role of HACCP and good hygiene practices.

He is a certified BowTie practitioner, and is one of the few food safety experts globally using BowTie methodology – a barrier, risk-based thinking approach to risk management in the food businesses. This approach enables businesses to build holistic, resilient and adaptive systems in a rapidly changing environment.

Andrew also works on supply chain management, agriculture and water use, animal feed and traceability. Plus, he’s part of the team that manages hygiene and allergen management.