SGS Societe Generale de Surveillance SA : SGS Survey: Lack of Clarity on Allergen Threshold Levels Leads to Excessive Precautionary Labelling and Consumer Uncertainty

(GENEVA, SWITZERLAND, 28 February, 2014) − Overuse of precautionary labeling, caused by uncertainty about allergen thresholds and control issues, causes confusion to consumers. Managing allergens is a shared responsibility.

SGS's recent Current Industry Practices on Allergen Control and Management survey, completed by food businesses in 46 countries, explores current allergen management practices and highlights gaps in knowledge that help to explain key practical challenges in the imlementation of effective control measures.

'Lack of concensus on universally agreed acceptable levels for allergens means that allergen risks are interpreted in different ways accross industry leading to the overuse of the fail-safe precautionary  labeling. Not only does that add to consumer confusion but it also forces consumers to largely ignore labels putting them at extra risk', says Dr. Evangelia Komitopoulou Global Technical Manager at SGS. 'At the same time, differing allergen-labeling regulations have increased operational complexity. As a result, labeling errors and product recalls have increased, reinforcing the need for harmonization across national boundaries', elaborates Komitopoulou.

The development and maintenance of an allergen control plan is one of the fundamentals of effective allergen management. The survey results indicated that about 29% of respondents do not have a corporate system in place. Although these operations can use local safety and management systems and in light of the latest FSMA regulations, the lack of a coordinated and corporate-level system is somewhat concerning.

Developed both in-house (43.5%) and in cooperation with external consultants (42%) allergen control/management systems cover a range of aspects. More than three quarters of respondents indicated that their system incorporated raw ingredient handling, 67% the manufacturing process, 59% labeling and 56% facility and equipment design. However, just 29.5% consider the risk of packaging as a source of allergens and 59% do not verify the allergenic state of packaging materials used in direct contact with raw ingredients.

Surprisingly, fewer than half of respondents include the supplier approval process within their allergen management program, and it comes only fourth in the list of tools used in allergen management − just 42% of respondents identified supplier audits/approval process as part of their process.

Unsurprisingly, HACCP is the most popular allergen management tool in currrent use (73%), followed by the risk assessment (57%), and traceability (56%). Two thirds of respondents also identified HACCP as a key part on allergen management. The industry's approach to allergen management, based on the classic HACCP concept, significantly reduces allergen risk by implementing appropriate controls (e.g. segragation, sanitation, traceability across the supply chain etc.). However, the absence of defined allergen threshold levels means all allergens are treated as posing the same level of risk.

As a result, food manufacturers err on the side of caution. Some 64% of respondents say that the potential presence of allergens in their products is communicated via precautionary "may contain" labeling. This results in the application of this type of labeling to more products than strictly necessary.

Allergen thresholds and the definition of internationally accepted allergen action levels (thresholds) were identified as the biggest acknowledge gap, by 67% of respondents. Improved definition of thresholds would facilitate more effective allergen risk assessment and management.

A quarter of respondents rely solely on supplier information to determine the presence or absence of allergens in raw ingredients, without taking any additional precautionary measures. The majority of respondents (75%) do have internal procedures to verify/validate supplier claims. These include reviewing certificates of analysis (56%), vendor questionnaires (42%), third party testing (41%) and ad hoc sampling of finished products (24%).

Respondents implement diverse approaches to minimize cross-contamination. Labeling allergenic engredients promptly and providing appropriate segregation of allergenic ingredients and finished products are the most popular actions, taken by 55% and 52% respectively. Interestingly, there was little difference in the response rate between organizations with a management system in place, and those without. This suggests that specific actions are taken, and activities implemented, even in the absence of a fuller system.

Just 44% of respondents indicated that they use training courses and events to ensure personnel keep up-to-date with the latest information on allergens, for example technical and regulatory news. Most rely on electronic communication, such as email and newsletter. As well as meetings to ensure this information is relayed. One fifth (20%) said they take all three actions in parallel.

Effective allergen management is a shared responsibility that involves all industries across the supply chain; regulators, health professionals and also consumers. Industry is responsible for adopting a systematic allergen risk assessment approach that will enable the effective control of cross-contamination risks and provide accurate allergen information to consumers to enable them to make an informed decision. Aligning the supply chain by building awareness, identifying, sharing and promoting best practices is one important step in effective allergen management.

SGS conducted the Current Industry Practices on Allergen Control and Management survey to understand current industry practices and challenges in the control and management of allergens from September to December 2013. The unique global survey attracted 230 responses from organizations in 46 countries, covering all types of business in the agriculture and food value chain.

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SGS will publish a white paper Allergen Management as a Part of Safe Global Food Supply in April 2014. The publication will highlight challenges and trends in allergen management with a focus on key elements of an effective allergen control plan. To pre-order your copy, please send your name, title and company name.

For more details, please contact:

Outi Helena Armstrong
SGS SA
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