Food & Nutrition Analysis:

Allergy Testing: What are the rules and how can you follow them?

SYNLAB Laboratories’ Dr Mike Bromley lifts the lid on the laws surrounding testing and labelling allergens for caterers in the UK.

Estimates suggest that between 1 and 5% of the world’s population have a clinically proven food allergy, with around 2 million people in the UK thought to be affected. For those affected by a food allergy, quality of life can be severely affected directly through exposure to an allergen or indirectly through the fear of being exposed. This fear is not unwarranted as the most recent reports suggest in the UK alone 5-10 people each year die because of food allergen exposure.

Allergens can be present in a wide and diverse range of foods. The presence of these allergens in our food is considered a significant health risk and regulation, in the guise of the Food Information for Consumers (FIC) legislation, specifies that the certain allergens must be declared if they are ingredients in our food. In its most recent incarnation, this legislation not only covers packaged food, but unpackaged food, any food sold in catering establishments and applies to food business operators at all stages of the food chain. This places an emphasis on food businesses to ensure allergen information is available to end consumers.

Stating that allergens are not present as ingredients is not the same as declaring a product is free from the allergen. This should be made overtly clear to customers so as to avoid confusion however this raises the question as to how this is communicated including the spectre of the ‘may contain…’ declaration. One particular section of the Food Information for Consumers (FIC) legislation makes indirect reference to this. It states that information provided on a voluntary basis ‘shall not mislead the customer’, ‘shall not be ambiguous’ and ‘shall be based on the relevant scientific data’. Some would argue that a blanket declaration that any allergen may be present could be misleading, and not based on available scientific (testing) data. Several companies have instead opted for a more informative approach stating that certain allergens are not used as ingredients in a specific product however the allergen is used on site or by their ingredient manufacturers.

For those companies that extend their declarations to free-from, the financial rewards are potentially lucrative. The free from food market has grown by an estimated 325% over the last 9 years to 2015 and is expected to exceed half a billion GBP sales in 2016 (Mintel). Leading UK retailers are leading the way in this field with Tesco recently heavily investing in the revamp of their own-brand free-from range. This is further evidence to suggest that it’s time for the food industry as a whole to respond to the growing market and cater for people with allergies and intolerances. As such, it remains vitally important that the science behind allergen labelling is sound, which is why implementing an effective allergen risk assessment procedure could have massive benefits for businesses in the hospitality and catering industries.

There are nuances to the rules surrounding allergens that all-to-often fly under the radar, for example, the definition of ‘free-from’ in some instances is vague. Most allergens do not have a legislated safe limit as insufficient scientific data is available to establish safe thresholds. Consensus has been derived in relation to gluten allergen. To label something as free-from gluten a food sample should contain no more than 20 parts per million (ppm) of gluten when tested.

The matter of establishing safe thresholds for other allergens is a continuing issue particularly because what might be deemed safe for one allergy sufferer may not be safe for another. This means that the thresholds that will eventually be identified as being ‘safe’ for the vast majority of the population probably will not be applicable to everyone. While research is ongoing the issue currently has no straightforward answer and for caterers this is yet another reason to seek advice before making free from declarations.

There are many prominent risk areas for caterers including: manufacturer contamination, staff-introduced contaminants, cross-contamination and even gaps in staff training or knowledge. The risks in hospitality and the food service industries in particular are heightened due to frequent changes in food type being prepared, minimal space for storage and the pressures of immediate service to consumers.

While these risks can generally be reduced or overcome with internal risk analysis, supplier checks, auditing and staff training, it is essential that the effectiveness of these measures be continually monitored. After all, even the most experienced and diligent of caterers can fall foul of complacency and the fact remains that caterers have the added pressure of being consistently customer-facing and on the ‘front line’ of the food industry’s supply chain. It’s therefore essential for caterers to be extremely vigilant and ensure they have best-practice procedures in place.

Unless catering providers employ on-site dedicated technical staff teams to make sure each allergen-detection procedure is followed rigorously, it’s inevitable that outside resources may need to be called upon in order to ensure compliancy and to safeguard the business as a whole. The sheer level of scientific knowledge and understanding required to ensure companies remain compliant with current legislation means that even the largest of firms will probably require some level of external support when it comes to testing for allergens and monitoring internal compliance procedures.

For smaller businesses on an even tighter budget, advances in technology have resulted in affordable and accessible allergen testing methods entering the market. The emergence of these new technologies mean that companies of all sizes should be able to minimise the risks that they may not have thought of previously, ensuring they are demonstrating awareness and care around allergen issues such as cross-contamination.

Dr Mike Bromley was the founder of Genon Laboratories, now part of SYNLAB,  and he is a lecturer in Medical Mycology at the University of Manchester.. 

SYNLAB, through the acquisition of Genon, are experts in food authenticity testing and developed ‘Test in a Box’ – an allergen testing kit specifically designed to be used on site for the catering and hospitality industries.

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