With Natasha’s Law coming into effect in the UK, what additional challenges do you think this poses SME food and beverage businesses?
Natasha’s Law will require business to provide a full ingredients declaration in descending order of weight, with correct technical legal descriptors. It’s a huge step change for the food service, catering and hospitality sector for their foods prepacked for direct sale.
Every business now needs to be competent in food technical labelling, irrespective of their size. Sufficient details have not historically been provided for purchased ingredients to support this level of ingredient declaration on finished products. Despite UK Food Standards Agency creating some useful guidance, many SMEs are not sure what is required and are struggling to prepare. UK local enforcement capacity is also at full stretch and unable to provide local help and support.
A likely unintended consequence scenario is that small operators will choose to no longer pre-pack or wrap their food to avoid having to provide full ingredients declarations. This could create new hygiene and food safety issues as products will be open for longer, risking cross-contamination from the surrounding environment of pathogens, foreign objects and allergens.
Now that Biden’s FASTER bill is expanding the definition of major food allergens to include sesame, how might a food manufacturing selling to US consumers have to adapt their quality controls?
Sesame is already required to be mandatory labelled as an allergen in over 20 countires. For food manufacturers in these markets or selling to these markets, there should be little or no impact on their operations of the US adding sesame to their allergens list. They should already have prerequisites, risk management and labelling in place. They will need to review and update their specifications and shipping documentation to ensure correct declaration of sesame. If a food manufacturer selling to the US has not previously included sesame in their current allergen risk management program, they will need to carry out a review and risk assessment of the presence and likelihood of cross-contamination from sesame in all products made and handled in their facilities.
Additional appropriate control measures may need to be put in place to manage sesame cross-contamination along with updates to specification and product declarations. As whole sesame seeds are notoriously difficult to handle and segregate, an increase in ‘may contain’ declarations for sesame on products entering the US market is a reasonable expectation. To avoid this, some manufacturers may decide to cease handling sesame in their facilities.
Are there any specific industries within food and beverage, or perhaps distribution to consumers, that may be affected by allergens and changes in mandatory declarations going forward?
The strong push to reduce the use of packaging is driving alternative formats where foods are sold loose for consumers to dispense themselves into their own reusable containers. This creates a new risk of allergen cross-contamination and hygiene controls for these organisations. Food is no longer enclosed with product integrity protected in these loose dispense formats. Extra vigilance is needed. Staff who have never before needed to address these risks will need training and monitoring procedures put in place to ensure effective cleaning and segregation at all times.
Prepacked foods continue to struggle to get allergen labelling correct, with allergen alerts still occurring weekly. Allergen labelling should be a ‘zero event’ similar to healthcare and occupational health approaches to risk management. Continued lack of understanding in the wider food sector, especially at board level, is preventing investment in training and systems to prevent these labelling errors. Future agreement by regulators of acceptable quantitative thresholds for food allergens to trigger use of precautionary advisory labels such as ‘may contain’ will layer in significant complexity. In many cases, current allergen risk management systems are not capable of incorporating such a step change and it is likely to cause disruption.
Food service, catering and hospitality continue to face the greatest challenge with allergen risk communication to their consumers. Recipes can change daily or even hourly, dependent on availability of ingredients. Business to business allergen information provision can be incomplete or not translated across to the final served food. Food safety cultures in kitchens often do not address food allergens or their risk management which can lead to wrong advice – whether verbal or written – with devastating consequences. Good practice does exist, often led by individuals who have family members with food allergy. A sector culture change is required to guarantee mandatory food allergen declarations are delivered pertinent to the allergen risk status of the food provided.
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