New changes on the way for allergen labelling and thresholds will help the industry take a more scientific approach to risk mitigation and are a welcome change, according to Betsy Craig, the CEO and founder of food allergy safety, nutritional labeling, and foodservice training company MenuTrinfo.
“I’m super excited now because we’re going off science and statistics and real documentation,” Craig said.
In July, Food Safety Magazine reported that the U.S. The Food and Drug Administration is changing its approach to allergen regulation and adopting a threshold-based approach.
Under current guidelines, allergen regulation requires labeling products if the ingredients contain nine specific allergens: sesame, soybeans, wheat, milk, eggs, fish, crustaceans, tree nuts, and peanuts. But the agency has not established specific allergen threshold levels and how they relate to labelling requirements. According to Food Safety Magazine, this is likely to change.
“While the current regime centers on ingredient disclosure, misbranding concepts, current good manufacturing practices (cGMPs), and preventive controls, a future framework could become more expressly risk-based and emphasize thresholds, reference doses, and validated cross-contact controls,” the article stated.
As it currently stands, the FDA does not require labels to address the possibility of allergen cross-contact. It only requires disclosure if it is used as an ingredient.
“What we’re seeing is a tightening up of what’s been loosely goosy for 20 years and has only gotten more so. This is starting to set up some pretty strong guardrails [around allergens] based on science and research,” Craig said.
She said that this transparency will help consumers make informed decisions.
“A lot of people can eat particles of their allergen and not end up sick. We need to start being more realistic about it,” Craig said, adding that “95% of people with a food allergy don’t get sick at ED05 (Eliciting Dose 05, the low exposure level threshold ).”
Craig also highlighted California SB68, which went into effect on July 1st, mandating that restaurants disclose allergen information on menus if they have 20 or more locations.
“This is the first statewide legislation that says that an item has specific allergens. For the community [of people with dangerous allergies], this transparency is really big.”
Craig said she believes laws like this will have a ripple effect and noted that 5 other states currently have similar pending legislation.
“It’s small restaurants and restaurant chains that are leading this new transparency to consumers.”
When asked what potential changes to allergen labelling would mean for food manufacturers, Craig said “it would mean fewer recalls. Less exposure to risk for consumers, and it means consumers can trust your labelling more.”
She noted that “allergens are the number one reason food gets recalled for Consumer Packaged Goods. It's so costly, and every manufacturer dreads it because it costs millions of dollars to recall a product.”
She added that “almost half the time the recall is because of mislabeling. It’s simple stuff that goes sideways, and then you need to recall the package because it was labeled wrong.”
Craig said that any reputable food manufacturer is already testing to meet allergen mitigation protocols; they just need to “tighten up what they’re already doing,” and ensure they can prove these measures to consumers, not just their own company supervisors.
Craig said the world is on a path to be safer for people with allergies.
“I believe it will be safer and the yardstick will be easier to see and measure. Everyone will know what the measurement is (for safe products) the same way that we all know what a foot is.”
But whatever safety advances are made, strict allergen control plans will remain essential.
“The allergen control plan is really the key to all of this. It’s about what allergens are present in the ingredients you’re using in manufacturing. Where are they kept? Are they isolated? Are they throughout the facility?” Craig said.
Considering that allergen label errors are the number one reason for allergen recalls, Craig said companies must be careful how they organize and track their labels and double-check label accuracy.
“Something as simple as somebody double-checking labels can prevent a recall, which can cost millions of dollars," she said.
She called for the segregation and color-coding of facilities to prevent cross-contamination and also recommended collaboration among food safety companies to help one another improve safety.
“Go get a fresh set of eyes on your operations from someone who is not a competitor. Tell them, come over here and give me a day in my plant and I’ll give you a day in yours. There’s no reason we don’t have great collaboration like that because people get blind and stop seeing things. It helps to have a fresh set of eyes."
Craig shared that her company has rolled out new training videos that are 3 minutes long because “we all have the attention span of a gnat, and so we have to do it really quick. So we teach about allergens in six or eight snippets where you are going to retain it.”
She also pushes for an approach to food safety that focuses on entry-level employees as the key factor.
“You are only as safe as the training of the lowest-paid employee on staff. The one that gets the smallest paycheck could be the one that separates you from success. So how are you training them?”