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Allergen management and labelling

In November 2001, we discussed the Institute of Food Technologists' (IFT) Scientific Status Summary on food allergies and other food sensitivities. It was noted then that regulatory authorities worldwide were responding to consumer concerns by increasing food labelling requirements with regard to potential allergens.

The Food Standards Code in Australia contains a requirement in Standard 1.2.3 for the mandatory declaration of certain substances and products derived from them. These materials are all linked to allergenicity or sensitivity. For packaged foods, the information must appear on the label. In other cases, the information must be shown with the food display or provided to consumers on request.

The materials that must be declared are:
  • cereals containing gluten and their products, namely wheat, rye, barley, oats and their hybridised strains, other than where these substances are present in beer and spirits standardised in Standards 2.7.2 and 2.7.5;
  • crustacea and their products;
  • eggs and egg products;
  • milk and milk products;
  • nuts and sesame seeds and their products;
  • peanuts and soybeans and their products;
  • added sulphites in concentrations of 10 mg/kg or more;
  • royal jelly presented as a food or royal jelly present in a food*;
  • bee pollen*; and
  • propolis*.
* These substances are not normally used as ingredients or components of processed foods.

While the problems associated with food allergies and sensitivities are now widely recognised by the food industry and regulators, the industry is still faced with a challenge to safeguard the health of all consumers and to comply with the Food Standards Code. This is primarily because food allergens can become part of a food through unintended exposure, i.e. contamination of a food with an allergen that is not meant to be present and therefore not declared on the label.

The Australian Food and Grocery Council has recognised the need of many manufacturers in this area and late last year released A Food Industry Guide to Allergen Management and Labelling. (PDF available here.)

Allergen management
This eight-page guide explains the nature of food allergies and the statutory requirements contained in the Food Standards Code with regard to potential allergens. Most importantly the guide contains a substantial section on allergen management and recommends controlling the possibility of allergen contamination through a HACCP approach. The guide advises 'the critical points during manufacture where allergens can be introduced into products should be identified and a system established to monitor these critical control points to ensure unintentional contamination is being controlled'.

The guide nominates key areas that food companies need to consider to control potential sources of food allergen risk and lists possible sources of contamination as:
  • raw materials;
  • accidental misformulation;
  • changes to product scheduling;
  • rework;
  • insufficient or ineffective cleaning/sanitation procedures;
  • in-process cross contamination; and
  • post process contamination.

All of the above are important control points and the guide pays particular attention to the manufacturing process. The guide notes that the production system design should minimise the amount of equipment exposed to any allergen. Manufacturers should identify areas, equipment and processes where allergenic ingredients may contaminate allergen-free foods. It is often necessary to designate specific manufacturing tools or equipment for allergen-containing products to avoid any chance of contamination. Where shared production equipment between allergen-free products and allergen-containing products is unavoidable, allergen-containing products should be run at the end of a shift immediately before cleaning. Cleaning following the processing of an allergen-containing product is essential. Equipment may need to be disassembled and manually cleaned to ensure hard to clean areas are free of allergen residue.

The guide comes out strongly against 'may contain' statements which appear on many current labels declaring such statements should never be used as a substitute for good manufacturing practice or to compensate for poor work practices.

The Australian Food and Grocery Council can be contacted by telephone at 02 6273 1466, or check www.afgc.org.au for further information.


Food Safety and Hygiene
Prepared by Keith Richardson and Rachel Jackson
Food Science Australia
PO Box 52, North Ryde 1670. Tel +61 2 9490 8397 Fax +61 2 9490 8499
Email enquiries@csiro.au