Customer Focused, Science Driven, Results Led

Allergen Control in Foodservice

Simon Flanagan

Senior Consultant Food Safety and Allergens

Overview

• ‘Free-from’ – key considerations

•Principles of allergen risk assessment in pre-packaged food sector

•Applying knowledge to the foodservice sector

•Hierarchy of allergen risks in foodservice

•Learning from previous research in the foodservice sector

Free-From - the Bar is Higher!

• Invitation to purchase by potentially most at risk consumers

• No such thing as zero but this is what many consumers expect!

• Only currently have legal limits for ‘gluten-free’

• In absence of limits many companies relying on positive release

(non-detectable at LOD / LOQ)

• Patchy regulation and sparse published best practice guidance

• Manufacturers, retailers and foodservice setting own polices

• Enforcement surveys

FSA Guidance

Food Standards Agency “Best Practice Guidance on Managing Allergens with Particular Reference to Avoiding Cross-Contamination” (2007)  Section 3.3.2 Allergen-free foodsA growing number of food manufacturers and retailers are providing ranges of substitute foods made without certain common allergenic foods, such as milk, egg or cereals containing gluten. In addition, some manufacturers choose to exclude certain allergens from a site. It should not be assumed that the lack of a need to use advisory allergen warnings entitles a product to make a ‘Free From’ or ‘made in allergen X free factory’ claim.  Consumers are likely to actively seek such products if they need to avoid particular ingredients and it is essential that any such claims are based on specific, rigorous controls to ensure their validity. …….An ‘allergen-free’ claim is an absolute claim, which may be interpreted by consumers to mean a complete absence, whereas the best that can be scientifically demonstrated at present is that samples of the food were shown to be below the analytical limit of detection of a testing method on one or more occasions.

Expected that any claim is based on a robust risk assessment

Principles Of Risk Analysis in Pre-Packaged Foods (FSA 2006)

Risk assessment - what's the risk?

Risk management - what's the risk?

Risk communication – how to warn consumers?

Risk review – has the risk changed?

Terminology (HSE 2009)

• Risk assessment – the semi-quantitative (or, in exceptional circumstances, quantitative) estimation of whether a hazard is likely to occur in practice; normally expressed as a risk factor or score by multiplying the hazard severity score by a likelihood score (unlikely (score 1), likely (score 2) or very likely (score 3)). All risk scores indicating other than low risk must be investigated and risk control/management procedures followed

• Hazard – a substance etc. which has the potential to be harmful. Hazards are very varied… The severity of the hazard is determined by possible consequences; for risk assessment, the severity of hazards is scored on a simple three point scale: minor injury or effect (score 1), major injury or effect (score 2) or death (score 3).

• Risk control/risk management – the means by which moderate or high risks identified through risk assessment are eliminated or reduced to acceptable levels

Can We Apply To Allergen Risk Assessment?

•Estimation of risk – subjective•Likelihood score – subjective•Severity of hazard

– Depends on the allergenic ingredient – Depends on sensitised individual– Spectrum of reaction in sensitised population from mild (1)

to death (3) •Risk management

– Eliminated (?) or reduced to acceptable level (?)– Cannot completely eliminate risk– What is an acceptable level (no thresholds)

Best Practice – Risk Assessment

•Targeted risk assessments incorporating hazard characterisation

•Evolution of 2006 FSA guidelines•Three-tier allergen mapping •Assessment of risks arising from the

following factors– Process flow– Environmental– Production – People

•Rank risk probability against characterised hazard•Output drives allergen management or labelling

Allergen Mapping (1)

Allergen Mapping (2)

Allergen Mapping (3)

Process FlowProcess Flow Examples

Ingredient weighing Cross- contamination from non-dedicated scoops

EnvironmentalEnvironmental Factors Examples

Warehouse Contamination of stored products due to air extract into warehouse

Production Production Related Activities Examples

Rework management Rework is not clearly identified

PeoplePeople Related Activities Examples

Hygiene Staff moving between different lines without washing hands

Probable Versus Remote

Hazard Characterisation (1) Allergen Biochemistry

• True allergens = always proteins

• Most allergens incredibly stable molecular structures

• Some resistant to processing– Heat treatment– Mechanical– Fermentation– Some rendered ‘more’ allergenic

• Biochemistry (and matrix) influence cleaning interventions

Hazard Characterisation6 Key Considerations

1. Physical nature of contaminant2. Level of processing undergone3. Amount of protein (no protein = no problem)4. Target consumers (vulnerable groups)5. Established thresholds6. Type of production environment

Characterise risk, define associated hazard and then validate existing control measures

Cleaning is significant control measure in the catering sector

Terminology

Cleaning Validation – Quantitative assessment of cleaning methods to ensure that

they are sufficient to minimise allergen cross-contact – Performed once unless anything changes

Cleaning Verification: Qualitative periodic assessments to confirm validated control measures (cleaning) are still effectivePerformed periodically at predefined intervals

• Monitoring of Cleaning– Qualitative ongoing assessments– Performed every time cleaning is undertaken

Output From Risk Assessment

Applying Concepts To Foodservice

Hierarchy Of Risks In Foodservice

Compositions Of Risk Assessment Team

Foodservice Research: Gluten-Free

•Staff training•Communication with allergic customer•Personal hygiene practices • Ingredient labelling• Ingredient storage•Preparation •Cleaning

Allergen Cleaning Project – Foodservice 2006

Results Summary PEANUT

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r-biopharmNEOGENTEPNEL2 per. Mov. Avg. (r-biopharm)2 per. Mov. Avg. (NEOGEN)2 per. Mov. Avg. (TEPNEL)

Learning from the Pre-Packaged Sector

• Recalls/withdrawals continued over last 7 years • Increased use of ‘may-contains’ – devaluation of warning • Common root cause 2008-2011 – inadequate training, packaging

errors and incorrect use of ingredients

Incidents by category, 2006 - 2011

Category 2006 2007 2008 2009 2010 2011

Allergens 61 86 84 86 79 114

Animal feed (on market) 9 10 13 10 8 28

Biocides 2 0 1 2 2 0

Counterfeit product 6 3 6 7 11 11

FSA Allergy Incidents 2011

Please Lets Try and Avoid This Approach!

Thanks For Your Attention