FHA 2014 International Conference
April 10 2014
2 NQAC AOA
Cleaning (one of the key control measures)
Introduction to Food allergy
Communication – Regulatory Requirements & Labelling
Communication – New EU Requirements
3 NQAC AOA
Various Types of Food Sensitivities
4 NQAC AOA
Food Allergy vs Food Intolerance
Food Allergy is an immune response to a food protein (food allergens).
Food Intolerance is a physiological response to specific food
component(s) or toxin mediated response (as in the case of food
poisoning). E.g. lactose intolerance, alcohol intolerance.
Sulphur dioxide / Sulphides / Sulphites
Sulphur dioxide / sulphides / sulphites can irritate the lungs and can send
an asthmatic into severe bronchospasm, a constriction of the lungs.
Sulphur dioxide / sulphides / sulphites are not true allergens but some
people (but not many) have positive skin allergy tests to sulphites
indicating true (IgE-mediated) allergy.
5 NQAC AOA
Food Allergy Response
Most food allergies are caused by hypersensitivities to particular proteins
in different foods.
• Some children who are allergic to cow's milk protein also show a cross
sensitivity to soy-based products;
• People with latex allergy often also develop allergies to bananas,
kiwifruit, avocados, and some other foods.
6 NQAC AOA
Food Safety Management System
• Hazard identification & characterisation
• Likelihood of occurrence vs severity on
• Prevention or Control measures
• Interactive exchange of scientific &
technical knowledge in risk analysis
• Validation, monitoring & verification
8 NQAC AOA
Presence of Food Allergens
• As an added ingredient.
• Cross-contact of an ingredient before or after it is received;
• Accidental ‘wrong’ formulation (from re-formulation; from batching
and/or tipping of wrong materials);
• Cross-contact by an allergen from a different product or due to sharing
of production line.
9 NQAC AOA
• Scope of today’s presentation
• The management involves:
• Incoming raw materials
• Packaging materials (printing of label)
• Manufacturing processes
• Product Innovation and Renovation
• Labelling & regulatory compliance
10 NQAC AOA
People Management in the management of allergens
• Awareness, knowledge, competence
• Right behaviours
• Personal hygiene (work wear, hand washing);
• Consumption of food and beverages at designated areas;
• Adhere strictly to work procedures and instructions during production.
11 NQAC AOA
Incoming Raw Materials
• Status (control measures at vendor production sites)
• Added allergen (especially in compound ingredients)
• Cross contamination during production; severity of the contamination
• Clear labelling
• Storage of allergenic raw materials should be segregated from other
non-allergenic raw materials;
• Dedicated tools
• Food dust during batching
• Allergen matrix Raw materials
12 NQAC AOA
• Reception procedure / Release for use
• Segregation to reduce cross contamination
• Correct usage
• Right product in right packaging
13 NQAC AOA
Allergen Management in manufacturing processes
• Risk assessment / hazard analysis / control points
• Reception procedure
• Dedicated line (best practice)
• Shared line
• Control measures to eliminate and/or minimise cross contamination
must be in place (validate, monitor & verify)
• Control measures could involve production scheduling; cleaning
during product change over.
• Allergen matrix
14 NQAC AOA
The most challenging aspect of allergen management in production is to
control cross contamination.
Cross contamination comes from:
• Sharing of production line for different products
• Sharing of utensils / tools / equipment
• Environment of production
• Environment of storage
• Use of compound materials
• Materials movements
15 NQAC AOA
Cleaning is an important control measure in the battle against cross
Types of cleaning
• Wet cleaning
• Controlled wet cleaning
• Dry cleaning
16 NQAC AOA
All cleaning should be validated, monitored and verified.
1. The validation should include proper qualification of design, installation
2. Monitoring should be done to ensure the cleaning achieves the
objective after each cleaning;
3. Verification on pre-determined frequency to ensure the cleaning
procedure remains effective over time.
4. Analysis methodology; Specification
17 NQAC AOA
Product Innovation & Renovation
• New product developed and renovation of existing product should
include management of allergen(s) that affect the health of target
• Value of the addition of an allergenic ingredient should be evaluated;
• Alternative non-allergenic ingredient should always be considered;
• Evaluate the impact on the production line (cross contamination) when
introducing an allergenic ingredient to the line;
• Availability of control measure to prevent/minimise cross contamination
• Impact on labelling (communication) and regulatory compliance in the
selling countries must be carefully evaluated.
18 NQAC AOA
Regulatory Requirements - Labelling
Legal requirements have been put into place to ensure the correct
labelling of foods in many countries.
In most cases, food labelling should inform the consumer of the presence
of known food allergens as an added ingredient in the food.
The legislation listed below is the EU, US, and Australia/New Zealand’s
requirements for food allergens:
• EU – Directive 2003/89/EC as regards to indication of the ingredients
present in foodstuffs.
• US – Public Law Section 201-210
• Australia/New Zealand – Food Code Standard 1.2.3
21 NQAC AOA
Communication - Labelling
• The process of approval of label must be carefully mapped.
• Process owner(s) must be clear.
• Those people who are tasked to approve label must have to
competence and knowledge to ensure there is no missing information
on the label.
• Declaration must be clear, accurate and complete.
• Declaration must be in compliance to the local regulatory requirement
where the products are being put on sale.
• When there is need to use multi-lingual labelling, translation must be
22 NQAC AOA
• Regulations in most countries do not mandate the declaration of
allergens being present in the finished product due to cross
• Most major global food manufacturers proactively label allergens from
cross contamination with precautionary labelling.
• Precautionary labelling refers to statements such as “may contain …
• Such statements should only be used as last resort after a series of
• Such statements should not be used as an alternative to GMP and
relevant control measures or as a cover-up of sub-optimal allergen
23 NQAC AOA
Allergen Labelling in Food Services
Keeping customers’ informed has been challenging for food service
outlets such as cafes, restaurants as well as catering services. In most
situations, customers or consumers would usually inform the service
outlets or catering services of special dietary requirements before
As in food production facilities, most of the allergen problems in food
service outlets arise from:
• Complex recipes.
• Cross contaminations such as shared cooking utensils and
24 NQAC AOA
Labelling – New EU Requirements
Labelling rules in European Directives 2003/89/EC and 2006/142/EC
ensure that all consumers are given comprehensive ingredient listing
information and make it easier for people with food allergies to identify
ingredients they need to avoid.
Following implementation of the Food Information for Consumers
Regulation (EU) No. 1169/2011, allergen labelling rules will be changing
in December 2014.
25 NQAC AOA
Labelling – New EU Requirements
The new regulation will introduce a new requirement for allergen
information to be provided for foods sold non-packed or pre-packed for
An example of
made by Food
26 NQAC AOA
Reference and Acknowledgement
Some of the materials presented have been taken from publications
(journals &/or online) of the following references:
• Campden BRI, Guideline 71 (2013). Food Allergens.
• Institute of Food Science and Technology (2013) Food Allergy
• Taylor, Steve and Hefle, Susan. (2001). Food Allergies and Other Food
Sensitivity. Food Technology, 55 (9), Page 68 – 83, Institute of Food
• Food Standards Agency, UK (2013). Advice on Food Allergen
• Nestlé Guidance on Cleaning Management.