Allergen Labelling: Exemptions & May be Present VITAL Phase 2 Allergen Bureau Seminar, April 2013 Julie Newlands & Georgina Christensen
Quick history of VITAL! 2002: ANZFSC Standard 1.2.3 -mandatory labelling of certain allergens (gluten, crustacea, egg, fish, milk, tree nuts, sesame seeds, peanuts and soybeans) -for intentionally added allergens only How do we label cross contact allergens? Absence of guidance meant that each company used it s own risk assessment A 2009 survey showed 42 statements!!
VITAL in place! VITAL was developed by industry for industry to determine when a precautionary statement should be used & when it should be avoided VITAL was launched in June 2007 & has undergone significant development VITAL end 2010: FSANZ - Food industry is addressing allergen labelling and precautionary labelling well Blewett - VITAL system be explored as a possible supplementary model to manage food label declarations
VITAL Outcomes Clear and consistent labelling for consumers to know when a product is safe for them to consume Appropriate labelling is a key outcome for VITAL
How do we form labelling outcomes from VITAL results?
VITAL Outcomes Source: p9 Food Industry Guide to VITAL Program http://www.allergenbureau.net/downloads/vital/vital-guidancedocument-15-may-2012.pdf
What information is available to help with forming label declarations? 1. Mandatory requirements (Australia New Zealand Food Standards Code) 2. Industry Code of Practice 3. Industry Guidance (E.g. information from the AFGC & the Allergen Bureau (VITAL Procedure, FAQs)) www.allergenbureau.net www.afgc.org.au
What information is available to help with forming label declarations? 1. Mandatory requirements (Australia New Zealand Food Standards Code & Trade Practices) & User Guides
2. Industry Codes of Practice example Many different Codes of Practice one example relevant to allergen labelling is: AFGC Code of Practice for Food Labelling and Promotion 2011 Includes: Daily Intake Guide Date Marking Allergen Labelling
Source: p44 AFGC Code of Practice for Food Labelling & Promotion http://www.afgc.org.au/industry-codes/cop-food-labelling-apromotion.html
3. Industry Guidance examples: AFGC: Food Industry Guide to Allergen Management and Labelling 2007 (under review) Allergen Management Testing & Analysis of Allergens Labelling VITAL
3. Industry Guidance examples: Food Industry Guide to the Voluntary Incidental Trace Allergen Labelling (VITAL) Program Developed by the Allergen Bureau Application of VITAL (VITAL Procedure) VITAL & Allergen Analysis
3. Industry Guidance examples: Unexpected Allergens in Food Collated by the Allergen Bureau from industry experience How to track down allergens! Download freely from www.allergenbureau.net
Is there enough guidance to ensure allergen labelling is appropriate? Do manufacturers know where to access existing guidance? Does the available guidance provide sufficient information for clarity & consistency of allergen labelling? Is there any a need to develop further or improve existing guidance?
Title? Format? Font? Specify allergens Ingredients: Water, Sunflower Oil, Onion, Thickener [(Maize Starch (1422)], Cream (Milk), Egg Yolk, Glucose Syrup (from wheat), Natural Flavours (Contain Milk & Fish Derivatives), Yeast Extract. Soy present in sunflower oil. Contains milk, egg, wheat, fish & soy. May be present: peanuts. Terminology
Allergen-related Activities 2013 FSANZ projects - Lupin as a mandatory allergen - Allergen exemptions - Clarification of FSANZ allergen terminology Allergen Bureau project - Allergen Labelling Exemptions project AFGC projects - Gluten- free application - Review of Allergen Management and Labelling Guide
Allergen Labelling Exemptions: Current exemptions: Cereals containing gluten and their products, where these substances are present in beer and spirits standardised in Standards 2.7.2 and 2.7.5 respectively Fish and fish products, isinglass derived from swim bladders and used as a clarifying agent in beer and wine Allergen Labelling Exemptions Working Group: Glucose syrup from wheat Soybean oil - RBD Soy derivatives tocopherols & phytosterols Plus distilled alcohols
VITAL 3 Phases Phase 1 Risk Review Harnessing the value of physical risk review and analysis to validate management decisions and assumptions Phase 2 Risk Communication (Labelling) Communicating accurately and consistently to the allergic consumer Phase 3 Certification Investigation TBC
VITAL Phase 2 Working Group To address: Is there a need to improve guidance? Do we want to work to improve the clarity & consistency of allergen labelling? Do we need to further develop guidance?
http://www.afgc.org.au/ industry-codes/cop-foodlabelling-a-promotion.html http:// www.allergenbureau.net/ downloads/vital/unexpected- Allergens-in-Food-18- April-2011.pdf