New approach to Implementing HACCP in the Catering Industry

1
Food Standards Agency Scotland
2
Food Allergen Labelling
3
What is food allergy and food intolerance?

• Food Allergy
• A reproducible adverse reaction to a food or food
  ingredient that involves the immune system - e.g.
  peanuts, tree nuts fish and shellfish, eggs and
  milk
• Food Intolerance
• A reproducible adverse reaction to a food or food
  ingredient that does not involve the immune
  system - e.g. lactose intolerance
• Gluten Intolerance

4
Possible Symptoms
Symptoms can appear within minutes, or up to
several hours after the person has eaten the food
they are allergic to. They can include

• rashes (usually very itchy)
• tingling sensation in the mouth
• swelling of the lips, tongue, face and throat
• difficulty breathing
• diarrhoea
• vomiting
• abdominal cramps
• and, on rare occasions, anaphylaxis

5
How common is food allergy?

• Prevalence of different food allergies not well
  established
• 20 - 30 of UK population think they have an
  adverse reaction to food
• Tests show 1-2 of adults and 5-8 of children
  have food allergies
• Recent FSA consumer research shows that 12 of
  consumers look at food labels for allergen
  information (Consumer Attitudes Survey 2004)

6
Types of Allergen Labelling

• Statutory Requirements
• Deliberate ingredients in pre-packed foods
• Voluntary Initiatives/Best Practice Guidance
• Accidental contaminants in pre-packed foods -
  May Contain labels
• Non pre-packed foods and foods pre-packed for
  direct sale

7
New EU Legislation Directive 2003/89/EC
Amends 2000/13/EC (OJ publication November 2003)

• Established a list of specified ingredients for
  which ingredients listing exemption should not
  apply because of link with allergy/intolerance
• Requires that products derived from these
  allergens be labelled with reference to that
  allergen
• Makes provision for the list to be revised

8
Directive 2003/89/EC
Specified allergens list

• Cereals containing gluten
• Crustaceans
• Eggs
• Milk
• Fish
• Peanuts

• Soybeans
• Nuts
• Sesame seeds
• Celery
• Mustard
• Sulphite (/gt10mg/kg or 1)

And products derived from them
9
Directive 2003/89/EC
Indication of allergenic ingredients on
pre-packed Foods

• Scope Total
• Covers all deliberately added allergenic
  ingredients and their derivatives
• Includes carry-over additives, additives used as
  processing aids and solvents and media for
  additives/flavourings
• Applies to alcoholic drinks
• Removes 25 rule

10
Directive 2003/89/EC

• Timing of Implementation
• Came into force 26 November 2004
• Compliance by 25 November 2005
• Products marked and labelled before this time can
  continue to be sold
• Implementing Domestic Legislation
• Food Labelling Amendment (Scotland) (No. 2)
  Regulations 2004

11
Drawing up a Provisional List of Exempt Derived
Ingredients

• Recognition that not all ingredients derived from
  allergenic foods may be allergenic
• Submissions from industry to the Commission
• EFSA consideration of the dossiers and published
  opinions
• Commission Directive 2005/26/EC - list of
  provisional exemptions
• EFSA responsible for reviewing this list

http//www.efsa.eu.int/science/nda/nda_opinions/ca
tindex_en.html
12
What about other derived products not on the
provisional list?

• Industry can make submissions for an exemption
  from labelling for other derived ingredients at
  any time
• Submissions should be supported by scientific
  information
• Dossiers will be examined by EFSA
• Final list of exemptions to be published by
  November 2007

13
Implementation of Directive 2005/26/EC

• Provisions of the Directive apply from 25
  November 2005
• Draft Food Labelling Amendment (No. 2) (Scotland)
  Regulations 2005 issued for consultation
• SSI laid before Parliament
• SSI to come into force

14
Correcting Directive 2005/63/EC

• Amended Directive 2005/26/EC
• 3 December deadline for adoption
• Implemented in Scotland by The Food Labelling
  (No. 3) (Scotland) Regulations 2005

15
Types of Allergen Labelling

• Statutory Requirements
• Deliberate ingredients in pre-packed foods
• Voluntary Initiatives/Best Practice Guidance
• Accidental contaminants in pre-packed foods -
  May Contain labels
• Non pre-packed foods and foods pre-packed for
  direct sale

16
May Contain Labelling

• History
• Anaphylaxis Campaign Report
• Focus Group Research
• Stakeholder Meetings
• Consumer Concerns
• Finding the warning label
• Do different wordings reflect different levels
• Restriction in choice

17
May Contain Labelling

• Development of best practice guidance for
  industry on when to use such labels
• Amalgamation of existing industry guidance
• Drafting group - involves all stakeholders
• Consultation period ended 6 December 2005
• To be published in summer 2006

18
Approach being taken in the guidance on May
Contain advisory labelling

• Hazard control approach, identifying
• particular hazards and where they occur
• how, at these points, the hazards identified can
  be controlled (reduced or eliminated)
• Leading to
• an assessment of the risk posed
• a determination of the appropriate level of
  advisory labelling

19
Possible wording for advisory labelling

• Possible options include
• may contain (traces of) X - to be used, for
  example, where the product may be contaminated in
  the factory
• ingredient Y may contain (traces of) X - to be
  used, for example, where an ingredient may be
  contaminated further back along the supply chain

20
Non Pre-packed Foods and Foods Pre-packed for
Direct Sale

• Provision of information on allergens
• Food Labelling Regulations 1996 - Definitions
• Initial Views
• Stakeholder Meetings
• The way forward

21
Current advice to caterers

• Food allergy and intolerance are important safety
  issues
• Caterers need to be able to answer consumers who
  ask for information on which ingredients are
  present in the foods being served
• But if caterers are not sure if an ingredient is
  present, they should say so and NEVER guess

22
www.food.gov.uk/safereating/allergyintol/caterers
23
Caterers - next steps

• Increasing awareness and use of this advice
• Training for caterers to include food allergy and
  intolerance issues
• Enforcement officers to include control of foods
  causing allergy and intolerance in discussions
  with food businesses
• Discussions with Hospitality Organisations

24
Contact Details

• Susan Pryde
• Address Food Standards Agency Scotland
• 6th Floor
• St Magnus House
• 25 Guild Street
• Aberdeen
• AB11 6NJ
• Telephone [phone]
• Email susan.pryde_at_foodstandards.gsi.gov.uk