It was in November 2017 at the Codex Committee on Food Hygiene when Australia and the United States proposed to develop a Code of Practice on Food Allergen Management for Food Business Operators. The purpose of this document was to provide guidance to both, food manufacturers as well as governments, to manage allergens in food production. Such guidance would include advice on avoidance of cross-contact and advice role of labelling, especially precautionary labelling.
Which types of allergies will the document address?
While often food allergy and food intolerance are used as synonymous, they are not the same. There are three main immune mechanism which can cause adverse health effects:
- immunoglobulin E (IgE)-mediated (the most typical food allergy immune reaction)
- non-IgE mediated (cell-mediated), and
- mixed IgE and non-IgE mediated
The scope of the document addresses measures that the industry can take to prevent all these three types of disorders.
What triggers Food Allergy Recalls?
Over the past years, jurisdictions regulating food allergens have seen an increasing number of products being recalled. In the United States, the number of food allergen-related recalls in 2016 was even higher than the number of spoilage/pathogen-related recalls. Australia performed an analysis of the causes for recalls between 2016 and 2017.
The most common reasons were:
- Lack of skills and knowledge of labelling requirements
- Supplier verification issues
- Packaging errors
- Accidental cross contact
Which Points will the Code of Practise Address?
- Definitions – what are food allergens requiring management and what is allergenic contamination (e.g., “cross-contact”).
- Role of competent authorities, food business operators and consumers – Enforcement agencies, food businesses and consumers all have a role in the risk management of food allergens. Understanding the nature of this issue, the appropriate control measures and the information needs of consumers, informs requirements for compliance and enforcement to deliver safe food outcomes.
- Training and supervision – best practice allergen management and awareness for employees.
- Raw materials – allergen management practices to minimise risk.
- Storage and distribution – identification and segregation of allergens.
- Manufacturing and food service – control measures, including equipment, process design and cleaning.
- Formulation and labelling – ensuring all allergens in the food are included on the label.
- Testing and analysis – validation and verification of allergen control.
- Risk management tools – Consumer complaints, corrective actions, recalls.
The Draft Version
Earlier this week, a draft document of the Code of Practise has been circulated for commenting. The draft consists of the following chapters:
- Primary Production
- Establishment – Design and Facilities
- Control of Operation
- Establishment – Maintenance and Sanitation
- Establishment – Personal Hygiene
- Transportation
- Consumer Awareness and Product Information
- Training
There are several points in the document which are under discussion, e.g. if dust can lead to cross-contamination.
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