You might well have thought that COVID concerns had taken over all branches of government activity – but not so. The Foods Standards Agency, while noting the issues, has refused to be distracted from its Food Hypersensitivity work. What is also good to realise – although I suspect that few do – is that all of their work is in the public domain so accessible by anyone who is interested. All of the information below, for example, comes from the report of the board meeting held on December 2nd and to be found here.
Its research programme excepted (this has been compromised by constrained access to clinical practitioners and food sensitive consumers) the FSA is working away at resolving the issues raised by PAL (the dreaded may contain labelling), its project to develop ‘at a glance’ information on allergen management, implementing Natasha’s law for Prepacked for Direct Sale Foods due to come into effect on 1st October this year and setting up a FARRM scheme – see below.
THE FSA’s position on PAL remains that ‘it should only be applied if, after thorough risk assessment and review of manufacturing processes, there is a likely presence of an allergen in a food product’. However, we all know that this is not what happens. And if anything the situation is getting worse.
‘The use of PAL has increased since 2012; the 2020 follow-up study on the food industry’s provision of allergen information for non-prepacked foods found that more than half (55%) of Food Business Operators (FBOs) said they used precautionary advice warnings on these foods. In 2012, just three in ten (29%) of FBOs used ‘may contain’ labelling specifically. Follow-up interviews found that the key drivers for using PAL were to ensure customer safety, but also to protect the business (i.e. the perception was that it would reduce business liability).’
As everyone recognises, it is a horribly difficult issue and not one that the FSA seems likely to solve in the short run at least. But they are trying – by attempting to:
- Improve understanding of the current risk management practices employed by FBOs, and current usage of thresholds, for example through the Australian Voluntary Incidental Trace Allergen (VITAL) Program
- Continue to work with the international Codex Committees to facilitate the international harmonisation of thresholds and assess whether current testing methods are robust enough for industry to consistently detect regulated allergens at those threshold levels for a range of foodstuffs.
- Work with industry to review current FSA guidance and explore the potential to develop industry set standards to ensure greater consistency in PAL application. (We wish.)
Food Allergy Safety Scheme
This is a scheme to produce ‘at a glance’ information on allergen management along the lines of the existing Food Hygiene Rating Scheme. However, it is as yet only at the scoping stage. What information, for example, do consumers actually want? Or, indeed, do they want any more than they are already getting? If they do, what is the best way to deliver that information? Should it be via digital apps, databases or catalogues? How could such a scheme align with other third party schemes already in existence or in development? How could one make such a scheme user friendly not only for hypersensitive consumers but for businesses, especially SMEs?
There has been – and is on going – a lot of work on how to communicate the new rules to food businesses and and to the consumers, especially the younger consumers, who will be particularly impacted by the these rules.
In that context the the FSA’s online training – directed primarily at local authority enforcement officers but also very useful for food industry businesses and even for interested consumers – has been revised and updated.
Food Allergic Reaction Reporting Mechanism (FARRM)
However, the project that I personally think is the most exciting – and will be of the most long term benefit to the allergy world – is their attempt to pull data together from the random groups who currently deal with serious allergic incidents, near misses or fatal allergic reactions.
We are all constantly told – and quite rightly – that data is king. If we do not know what is going on, how can we hope to be able to manage, or improve our management of situations. Up till now there has been little communication, if any between ambulance crews called to allergic emergencies, hospital emergency units to which cases are taken, GP practices caring for those allergic patients, local authorities managing allergy provision, outlets where allergy incidents may have occurred, coroners in cases of death, the courts if these issues come to court.
The FARRM project has therefore commissioned ‘discovery work’ to establish what real time information would be most useful in helping local authorities in particular to interact with food businesses at an early stage – and what other groups could usefully be involved and benefit from such information sharing.
We look forward to an update on all of these projects in the next Board Meeting report.