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Advisory food labels: consumers with allergies need more than “traces” of information

BMJ 2011; 343 doi: https://doi.org/10.1136/bmj.d6180 (Published 13 October 2011) Cite this as: BMJ 2011;343:d6180

Rapid Response:

Food allergy information and deriving action levels for use

We agree that consumers with food allergies need clear information
about allergenic ingredients and allergen cross-contamination risks.
However changes to existing practices need to be based on robust
scientific evidence. Improving the provision of food allergen information
is a priority for the UK Food Standards Agency and it has an active
programme of research which includes the development of allergen action
levels.

Since the publication of its best practice guidance on allergen
management in 2006, the FSA has been working with the food industry, other
regulators, clinicians and consumer groups to review the current evidence
and new data coming from large studies such as EuroPrevall to ascertain
whether there were sufficient data to derive workable action levels for
allergens (Madsen et al 2007, Chan et al 2011).

During discussions at a number of international workshops co-funded
by the FSA, it has been agreed that zero risk is not possible. There is a
need to consider a tolerable level of risk (Madsen et al 2010, Madsen et
al - in press) in order to provide choice and certainty for the allergic
consumer whilst ensuring that the action levels chosen are practical and
feasible for the food industry.

The recently agreed EU Food Information for consumers Regulation will
allow the European Commission to set out requirements for information on
possible and unintentional allergen cross-contamination.

While schemes elsewhere in the world, such as VITAL, have set out
action levels upon which allergen labelling decisions can be based, the
action levels within this scheme are currently under review. Other
initiatives on the development of allergen action levels, including that
from the International Life Sciences Institute's Food Allergy Task Force,
are also due to report in the next 12 months. We therefore expect that
there will be significant advances made in the coming months that will
give the food industry the information they need to make consistent
allergen advisory labelling decisions and which will provide more
certainty and choice for food allergic consumers.

Where cross-contamination with allergens is unavoidable or cannot be
reduced, the use of allergen advisory labelling such as "may contain 'x'"
or "not suitable for those with an 'x' allergy" is applied. The use of
allergen advisory labelling does remain high and the FSA is commissioning
a survey to determine the prevalence of allergen advisory labelling, and
the presence of allergens in foods with and without such labelling. But it
is important to remember that the risk of allergen cross-contamination in
a food product may not be homogenous, such as with pieces of nut. Allergen
advisory labelling decisions have to take account of the risk across the
whole batch rather than from an individual item.

Chan CH, McClain S, Mackie A, Hattersley S, Cochrane S (2011)
Frontiers in Food Allergen Risk Assessment, ILSI Europe Report Series 1:1-
26

Madsen CB, Hattersley S, Buck J, Gendel SM, Houben GF, Hourihane JO,
Mackie A, Mills EN, Norhede P, Taylor SL, Crevel RW. (2009) Approaches to
risk assessment in food allergy: report from a workshop ''developing a
framework for assessing the risk from allergenic foods". Food Chem Toxicol
47(2) p480-9

Madsen CB, Crevel R, Chan CH, Dubois AE, DunnGalvin A, Flokstra-de
Blok BM, Gowland MH, Hattersley S, Hourihane JO, Norhede P, Pfaff S, Rowe
G, Schnadt S, Vlieg-Boerstra BJ. (2010) Food allergy: stakeholder
perspectives on acceptable risk. Regul Toxicol Pharmacol. 57, p256-65

Madsen CB, Hattersley S, Allen KJ, Beyer K, Chan C-H, Godefroy SB,
Mills ENC, Munoz-Furlong A, Schnadt S, Ward R, Wickman M, Crevel R. Can we
define a Tolerable Level of Risk in Food Allergy? Report from a
EuroPrevall/UK Food Standards Agency workshop - In press

Turner PJ, Kemp AS, Campbell DE (2011) Advisory food labels:
consumers with allergies need more than "traces" of information
BMJ;343:doi:10.1136/bmj.d6180

Competing interests: No competing interests

02 November 2011
Chun-Han Chan
Senior Scientific Officer
Sue Hattersley, Head of Food Allergy Branch
Food Standards Agency