This article was previously published in the December 2016 -issue of the AOAC International Food Allergen Community – A presentation on this topic was made at the 4th Food Allergy and Anaphylaxis Meeting – in 2016.
Over the last 20 years, several actions have been taken by various players with the aim to enhance the protection of food allergic consumers. While several measures targeting the improvement of ingredient labelling, with emphasis on allergenic ingredients, have been harmonized thanks to standards promulgated by the Codex Alimentarius Commission, far more needs to be done in relation to the use of precautionary statements. Allergen precautionary statements continue to be diverse, to be used under different conditions and are not necessarily supported by risk assessment. As a result, these labelling practices are not helpful to consumers.
When one examines the history of food allergen management, it is easy to note that most regulatory measures that were developed at the national level took place after the Codex Alimentarium Commission known as Codex and acting as the international food standard setting body, developed its global standard on food allergen labelling in 1999. Several years were required, and expert advice was mobilized at the global level by the World Health Organization (WHO) and the Food and Agriculture Organization (FAO) of the United Nations to come-up with a set of criteria for the identification of food ingredients that have the potential to be allergenic. These ingredients were then covered by mandatory declaration on food labels.
Several domestic food regulatory policies were then amended and the world witnessed the development of a number of allergen labelling regulations and legislations in Australia/New-Zealand, Europe, the United States of America, Japan, Canada and a number of emerging economies in Latin America and Asia.
All these requirements were based on the Codex Standard and ensured to prevent the omission of declaration of food ingredients known to be priority allergens, when these ingredients are deliberately added to the recipe of a prepackaged food.
This did not however address all issues allergic consumers and their care givers are having with food labels. The propagation of use of allergen precautionary or advisory labeling in the form of “may contain” statements and other iterations is undermining consumers’ confidence and their trust in the reliability of information offered by food labels.
While precautionary statements were initially meant to address situations of possible cross-contamination due to an allergenic ingredient, which cannot be avoided under reasonable food processing conditions, there was no clear guidance as to how they should be applied in a manner that is risk based.
Statements of different types are popping on food labels, with no regard to what they may mean or what they can do to help informing the choice of allergic consumers and their families. Others are being used with no particular justification, other than to “cover a potential liability”. The practice has even led to witnessing precautionary statements on food labels that cover the entire list of priority allergens and that are longer than the list of ingredients itself. No wonder that confusion reigns, not only for consumers, but also amongst the health professional community, whose guidance is sought in helping allergic consumers manage their avoidance of potentially offending foods.
The scientific community acknowledged the problem and agreed that investing in the development of the scientific foundations for a risk-based approach to be applied would contribute to addressing this problem. A decade later, several studies resulted in the generation of thousands of data points related to thresholds for food allergen reactions. Risk assessment methodologies have also been discussed and are being adapted to food allergens as a food hazard. Allergen analytical methods have been developed and are being used to help validate sanitation practices and other quality control and management measures. We have even witnessed the development and adoption of allergen control programs by the food industry sector in an attempt to create “order and structure” as to how allergen advisory labeling should be used.
While food allergen-related recalls continue to top the list of food recalls in North America, Europe and some parts of Australasia, there is limited to no leadership from domestic food regulatory jurisdictions to move forward with clear regulatory measures focusing on allergen precautionary statements. Such measures would be the cornerstone for a more predictable environment for industry and consumers on food allergen management.
Learning from history to address this conundrum can be useful in this case. I would argue that like what happened in the 1990s and early 2000s, it is time for Codex and its parent organizations to act. Attention needs to be given to the development of global guidance related to allergen thresholds, allergen precautionary labeling and management of cross-contamination and adventitious presence of priority allergens in food manufacturing. These global standards could then lead the way in driving change in domestic food regulatory requirements in this area, which could then use the legitimacy of the international process. The time has come for Codex to lead again on this issue.
I realize that suggesting such an approach, can be met with cynicism, given how long some international food standards can take in the making. But Codex has also shown that when its membership wants, it can. The first Melamine standards that Codex embarked on developing in 2009, took only one year between decision to act and adoption of the standard, making it the fastest agreed-upon Codex standard to date. Opponents to this approach would also argue that there is currently no interest on the part of Codex to work in this area, nor would there be resources made available. My argument back is that momentum can indeed be created. The case can be made for Codex standards being needed, given the discrepancies of food allergen management policies and their impacts on international food trade. The case can also be made that scientific data has been generated over the past decade or more and could be relied-upon for international expert groups to be convened by FAO and WHO, to guide Codex with the relevant scientific advice. Finally, and should there be a will to act, funding could be mobilized from various government organizations currently struggling to move forward with addressing this issue and who would benefit from pooling resources under the auspices of a collective initiative.
It is possible for history to repeat itself. Twenty (20) years after the initiation of the process that led to allergen labeling measures as we know them influenced by Codex leadership, action leading to renewed international guidance on food allergen management is overdue.
Samuel B. Godefroy, Full Professor, Department of Food Science, Food Risk Analysis and Regulatory Excellence Platform, Institute of Nutrition and Functional Foods (INAF), Université Laval, Québec, QC., Canada &
Global Institute for Food Security, Queen’s University, Belfast, United Kingdom
AOAC International Newsletter – where the article is posted.