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At this year’s GFSI conference, SGS sponsored a breakfast session on “Allergen management - an integral part of a safe food supply chain”. Moderated by Dr Evangelia Komitopoulou, SGS’s Global Technical Manager for Food, the session introduced key findings of the industry survey on allergen management practices conducted by SGS, in the last quarter of 2013. A panel of experts also discussed practical challenges in effective allergen management implementation, including representatives from Cargill, Walmart and University of Nebraska, elaborating on recommended best practices, expected supplier allergen control practices and definition of allergen threshold levels.

The session attracted more than 250 delegates and prompted some meaningful discussions on current industry challenges and trends, as well as calls for action towards harmonisation between implementation measures, that can ensure consistency of allergen management across the world’s supply chain.

The survey, conducted by SGS, aimed to identify current industry practices on allergen management, highlight key industry challenges and potential gaps in the area. The survey ran for three months and attracted 230 responses from a range of different companies across the food and drinks sector. Responses were received from 46 countries. The survey included 27 questions covering the main principles of allergen management such as staff training, risk assessment, prevention of cross contamination and supplier management. 

SGS Survey: Lack of Clarity on Allergen Threshold Levels Leads to Excessive Precautionary Labelling and Consumer Uncertainty

Key findings of the survey presented during the session, involved the tools used in allergen management and prevention of allergen cross contamination and supplier approval practices. Gaps in knowledge and industry support needs on allergen management were also presented. The results of the survey indicated that almost a third of respondents (29%) do not operate a corporate allergen management/control plan. Of those that do operate a corporate allergen plan, only about 50% included supplier management as part of that plan, and only about 29% identify packaging as a potential source of allergens identified within their plans.

HACCP was identified as the number one tool used in allergen management, in combination in some cases, with risk assessment and traceability. At the same time, supplier audits as part of a wider supplier approval process came fourth in the list of tools used. More than 25% of respondents indicated that they rely on information provided by the suppliers, without including any additional internal verification processes. Just over half of respondents indicated they review the status of approved suppliers once a year and slightly fewer said that their supplier audits are not simply a desk-top exercise, but include on-site audits. In some cases (26%) those audits are unannounced.

The lack of a clear definition and/or consensus on allergen threshold levels has been selected as the number one knowledge gap (67.1%), followed by the development and validation of analytical testing methodologies, labelling regulations on unintentional allergen cross contamination (46.6%) and effective cleaning methodologies (41.8%). These results tie-in well with industry needs; the need for support on allergen risk assessment was top of the list (45.9%), followed by allergen labelling (36.3%).

Industry faces the challenge of ensuring consistency in allergen management across the supply chain, while the inconsistent use of allergen risk communication (declaration of allergens on the label), increases consumer confusion. The survey results demonstrate that industry is aware of, and is currently using some of, the known key elements of effective allergen management (e.g. segregation, HACCP, staff training etc). Despite that, allergen related product recalls are on the rise in the EU while in the US, undeclared allergens accounted for 40% of total products recalls in the third quarter of 2013 alone. 

Allergen Management Approaches Need to be Customised

Each operation is different and therefore a one-size fits-all solution would not be effective. Allergen management approaches should be designed to meet individual specifications, needs and requirements. However, in most, if not all cases, effective allergen management relies on three constituents:

(i) Top management commitment to approve necessary reforms.
(ii) Staff training designed around specific operations, job responsibilities, roles and individual involvement in the allergen management process, needs to be regularly reviewed and updated to establish and ensure continuous compliance.
(iii) Consistent implementation of standard operating procedures (SOPs) that need to be in place to cover key elements of the operation (e.g. cleaning and training).

Industry recognises the need to reach a consensus on allergen threshold levels. This will help businesses to adopt a consistent approach to allergen risk interpretation, and therefore management, as well as minimising the use of precautionary labelling (“may contain” labels on packs).

Precautionary labelling reduces allergenic consumer purchasing options. It also increases confusion as to what is safe to eat, or not. While it is generally recognised as a fail-safe, overuse could lead to consumers ignoring them, potentially exposing them to a greater risk. Extensive reviews of the current clinical and other research related to food allergen thresholds has been carried out by reputable organisations, such as The Allergen Bureau in Australia and New Zealand, Food Allergy Research and Resource Program (FARRP), TNO and the International Life Sciences Institute (ILSI) in an effort to propose safe allergen reference doses that could be used by food industry, regulators and others. However, it is expected that it will be some time before multi-stakeholder consensus is reached and before regulatory agencies endorse them. Due to the complexity and likely operational impact, it is imperative that industry continues to be kept up to date on the status of allergen threshold levels and their use in allergen risk management.

A Shared Responsibility

More and more companies require suppliers to be GFSI certified if they are to be included in their list of approved suppliers. Beyond that, a number of manufacturers and retailers operate additional allergen control practices and require their suppliers to comply and prove compliance. Internal label reviews, equipment/tool and people traffic within a facility, cleaning protocols that are validated and verified, as well as systems that manage the information on incoming raw ingredients, are just a few examples of such control practices. Based on the survey results, and looking at product recalls related to raw ingredient supplier issues extending beyond allergens, there is no doubt that supplier management is a weak link in the overall allergen management process. This requires a deeper look into the process of qualifying and approving suppliers, a requirement for all GFSI- benchmarked schemes.

Effective allergen management is a shared responsibility that involves the whole supply chain. Aligning the supply chain by building awareness, identifying, sharing and promoting best practices is one important step in effective allergen management. Different operations have different needs, but there is no harm in sharing best practices that can ensure food is safe wherever we are in the world.

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