Led By Nadia Narine

This presentation provides an overview of the current situation regarding allergen threshold limits and control legislation, and strategies and approaches for managing the associated risk.

In addition, developments in allergen management in food processing, recommended cleaning practices, hygienic design, and how to monitor, verify and validate allergen cleaning, will also be discussed.

Food allergens continue to represent a major hazard and concern to food safety worldwide. Although harmless to the majority of consumers, the amount of an allergenic foodstuff an allergic consumer will react to, and the severity of that reaction, varies enormously depending on their personal tolerance and state of health. Although much work has been done to determine thresholds/no adverse effect levels, and use them in food safety risk assessment, an agreement has not yet been reached on how to interpret this information for the benefit of public health.

For those that are intolerant or allergic, clear, and accurate information about the composition of the foods they eat is essential. Unfortunately, every year, a significant number of food recalls are related primarily to errors in product labelling.

The U.S. Food Safety Modernization Act has identified food allergens as a “foreseeable hazard requiring Preventive Controls” and requires that food facilities implement “preventive controls” to minimize the risk of unintended allergen cross-contact with food. Additionally, the Food Allergy Safety, Treatment, Education, and Research Act (FASTER) of 2021 was recently signed into U.S. law, and (effective from January 1, 2023) adds sesame to the list of 8 major U.S. allergens, for purposes of explicit product labelling.

Similarly in Europe, from 1st October 2021, in the UK (except Scotland) allergen awareness through product labelling has been strengthened through a new legal requirement to label foods that are prepacked for direct sale (PPDS) with allergen information. However, currently is there no legislation explicitly covering Precautionary Allergen Labelling (PAL). Approaches like PAL are primarily applied on a voluntary basis, without clear guidance, allowing food business operators and enforcement authorities in different countries to apply PAL inconsistently.

Other reasons for food recalls relate to the presence of unknown, undeclared allergens, or cross-contamination of an allergen-free product. Logistically, completely segregated manufacture of foods that contain allergens and are allergen-free, is often untenable. Consequently, segregation and cleaning remain major food safety controls within a factory producing both types of products.