FOOD ALLERGEN MANAGEMENT TOOLKIT Canadian Spice Association AGM May 6, 2016 Presented by Tiina Henkusens Anthony Gene Andrew Sweet
Agenda � Allergen Labelling & Allergen Management Resources � Allergen Control Program � Analytical Services
RESOURCES
Changing Regulatory Environment Canada’s food allergen labelling • regulations came into force August 4, 2012 2007 Food Safety Action Plan • enhanced surveillance initiative, targeted surveys were used by CFIA between 2010 – 2012 to evaluate various foods for specific hazards Increased oversight of imports, • exports & domestic production with CFIA modernization & Safe Foods for Canadians Act/Regulations
International Food Allergens Increase in global trade • Food allergen laws • vary by region Manage food allergens • according to the receiving country’s requirements Source: http://farrp.unl.edu/f0c3a875- ce07-404f-b05f-8a7983e57daa.pdf
Health Canada – Allergen Labelling � Health Canada's Amendments to the Food Allergen Labelling Regulations � Health Canada's Position on Highly Refined Oils Derived from Food Allergen Sources � Mustard: A Priority Food Allergen in Canada - A Systematic Review
Health Canada – Precautionary Allergen Statements � Health Canada's policy for enhancing the protection of food-allergic consumers in Canada is based on two guiding principles: ◦ prevent the inadvertent consumption of undeclared allergens by sensitive consumers; and ◦ enable a variety of safe and nutritious food choices for the allergic consumer � Precautionary labelling should only be used when, despite all reasonable measures, the inadvertent presence of allergens in food is unavoidable � It must not be used when an allergen or allergen-containing ingredient is deliberately added to a food or when there is no real risk of an allergen being present in the food � "may contain [X]”, where X is the name by which the allergen is commonly known � http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/precaution_label-etiquette-eng.php
CFIA – HACCP Generic Model for Spices Example, � In an effort to help reduce the risk associated with spices and assist manufacturers that wish to adopt a Hazard Analysis Critical Control Point (HACCP) approach, CFIA has developed the Food Safety Practices Guidance for Spice Manufacturers document � Applies to Div 7 spices http://www.inspection.gc.ca/food/safe-food-production-systems/haccp-generic-models-and-guidance- documents/guidance-spices/eng/1366340448103/1366340494598?chap=0#c1
Health Canada / CFIA - Gluten Free � A gluten-free claim is any representation in labelling or advertising that states, suggests or implies that a food is gluten-free, as per B.24.018 of the Food and Drug Regulations (FDR) � Foods containing gluten as a result of intentional addition may not be represented as being gluten-free. However, if a manufacturer using a cereal-derived ingredient includes additional processing steps which are demonstrated to be effective in removing gluten, the food may be represented as gluten-free. � Any gluten that is present due to cross-contamination in a food labelled gluten-free should be as low as reasonably achievable and must not surpass 20 ppm of gluten, a level that is considered protective for the majority of people with Celiac disease
Health Canada / CFIA - Gluten Free � In instances where the gluten is present due to cross-contamination at a level of less than 20 ppm in the food, the CFIA will follow up with the manufacturer or importer regarding the presence of gluten in the product. These manufacturers and importers should have good manufacturing/importing practices (GMP/GIP) in place to achieve the lowest levels of gluten possible to avoid cross-contamination. However, based on Health Canada's position, enforcement action on products containing less than 20 ppm gluten as a result of cross-contamination will not include a recall of the product, nor a request to remove the gluten-free claim � In all instances, regardless of source, if more than 20 ppm of gluten is present in a food labelled as gluten-free, the product may be in violation of the FDR Section B.24.018 and/or Section 5.1 of the Food and Drugs Act (FDA) and, on the basis of a health risk assessment provided by Health Canada, subject to appropriate enforcement action by the CFIA, which may include the possibility of recall � http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/allergens-and- gluten/eng/1388152325341/1388152326591?chap=2 � http://www.hc-sc.gc.ca/fn-an/securit/allerg/cel-coe/avoine-gluten-oats-eng.php
Allergen-Free Claims � General claims stating only "Allergen Free" or "No Allergens" are considered to be too broad in nature and are therefore not acceptable. The list of potential food allergen sources is not restricted to the list of priority food allergens identified by Health Canada. � There are over 200 food proteins that can cause adverse reactions to some segments of the population. Therefore, it is likely to create an erroneous impression to state that a product is free of allergens � http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/allergens-and- gluten/eng/1388152325341/1388152326591?chap=0
CFIA Targeted Surveys – Ground Spices � As part of the 2007 Food Safety Action Plan enhanced surveillance initiative, targeted surveys were used by CFIA to evaluate various foods for specific hazards � In 2010-11, a total of 268 ground spices were analysed for the presence of gluten � Gluten is not permitted in single pre-packaged ground spices. It is therefore expected that single ground spices do not contain gluten; the unexpected presence of gluten may pose a health risk for sensitive individuals � http://www.inspection.gc.ca/about-the-cfia/newsroom/news- releases/2012-08-15/eng/1344951042395/1344951257435
CFIA Targeted Surveys – Ground Spices � Of the 268 samples, 63 samples (24%) contained detectable levels of gluten ranging from 5 ppm to 20,000 ppm. � A number of factors are considered when determining if a food poses a health risk. The amount of the hazard, in this case gluten, that a person would ingest during a typical meal is a primary consideration. For single ground spices a serving size is relatively small at approximately 0.5 g. � It was determined, in consultation with Health Canada, that 62 (97%) of the spices with detectable levels of gluten did not pose a risk to sensitive individuals. One sample of mace was determined to be in violation of the FDA and FDR. This product was recalled.
CFIA Targeted Surveys – Flavour Packets 2010 – 2011 allergen survey targeted a variety of flavour packets including: � bake mixes, dessert mixes, sauce mixes, powdered drink mixes, seasonings, spices mixes and soup bases In 2014-2015, the CFIA conducted a follow-up survey. Any findings of � undeclared allergens from the survey may be considered to be in violation of Section 5(1) of the Food and Drugs Act if allergens are added and not declared. 2010-2011 Survey Results for Gluten http://www.inspection.gc.ca/food/labelling/foo d-labelling-for-industry/list-of-ingredients- and-allergens/industry-notice-2013-07- 08/eng/1373289087016/1426168102706
Additional Resources � ASTA � Food Allergy Research and Resource Program (FARRP) ◦ University of Nebraska - Profs. Steve Taylor, Joseph Baumert, Melanie Downs, Richard Goodman and Philip Johnson serve as faculty members in the Department ◦ Analytical services, resources, research, workshops ◦ http://farrp.unl.edu/ � Food Allergy Canada ◦ http://foodallergycanada.ca/
ALLERGEN CONTROL PROGRAM
Allergen Control Program � A requirement for any GFSI Programs � Points for Consideration: � Ingredient Cycle throughout the supply chain � Product Cycle within the process � Programs for claims, such as, Gluten free status � Process Review for claims: � How are Raw Materials verified � Implementation of a risked base testing program or assessment steps on raw materials � Risk assessment for cross contamination � Validation data for the process and the product
Auditing Process � Validation data for the process available for review � Employee knowledge: � At the plant level � T echnical team � Tools utilized to communicate allergens across all levels � Ingredient storage
Allergen Communication � Establish clear and accurate company policy on allergen labelling � Develop communication strategies with service team: � How to answer questions on food allergies efficiently � Provide regularly updated information � Keep communication simple and clear: � Written, labelling, consumer services, Websites, etc. � Refer consumers to organizations for people with food allergies
ANALYICAL SERVICES
Allergens Overview May 3, 2016 Presented by Andrew Sweet
Agenda Maxxam – Who we Are? ● Allergens ● Common Kits in use ● How does it work? ● Sensitivity ● Common issues ● Any changes coming? ●
A Canadian Market Leader
A Maxxam snapshot 24 May 3, 2016
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