The Chartered Trading Standards Institute (CTSI) has just issued a report, discussed in an excellent post on Alex Gazzola’s Allergy Insight blog, which makes it quite clear that being labelled vegan does not mean that a food is safe for those with allergies to milk or eggs. They found that over 30% of foods labelled ‘vegan’ had traces of milk or egg. And a trace is quite enough to kill someone who is seriously allergic to either, as in the case of Celia Marsh who died in 2017 after eating a ‘vegan’ flatbread which contained traces of milk.
The vegan revolution has been great for the ‘freefrom’ community in many ways. As we saw in this year’s FreeFrom Food Awards it has enormously increased the range of milk and egg free foods on offer and has stimulated new product development in areas like vegan ‘cheese’ which has resulted in some really excellent products. But it comes, for now at least, with this potentially fatal sting in the tail: not only may 30% of those foods be contaminated, but three quarters of consumers are not aware that they might be. Fine if only your conscience is at risk – totally not fine if it is your life.
One of the issues for the freefrom community is that the Vegan Society do not see contamination as a problem – although they do recognise that it is one for those who are allergic. For them it is all in the ‘intent’ – so as long as you did not ‘mean’ your product to contain dairy or egg, if it picks up a bit on the way that is not an issue.
Personally, I cannot see that this makes much sense. Either you do want to eat animal products or you don’t. How great the amount and whether it was there on purpose or by accident does not really seem to be relevant. As it happens that is (or at least was) the government/Food Standards Agency view. Guidance issued in 2016 and highlighted by Alex in his blog specifically states that:
Manufacturers, retailers and caterers should be able to demonstrate that foods presented as ‘vegetarian’ or ‘vegan’ have not been contaminated with non-vegetarian or non-vegan foods during storage, preparation, cooking or display.
However, as Alex points out, this never appears to have been enforced and has now been quietly dropped.
While no solution is ever perfect, this situation could be made so much more manageable if only the thresholds for allergen reactions, which have been being discussed for the last 20 years, could actually be agreed.
A threshold for a reaction is the milligram amount of an allergic protein that can be consumed by all except the most sensitive of the allergic population without them suffering an adverse reaction.
The importance of this to both the allergic community and the food industry is that it gives them both a level of contamination to which they can work, just as they currently have for gluten. So while it is 10 parts per million for gluten, it could be 2 parts or 5 parts per million for peanuts or egg or milk. But whatever it is manufacturers have some certainty on what is allowed and can be tested for and either their product meets that requirement or it doesn’t. If it does then the product is free of that allergen and can claim to be so, if it doesn’t then it isn’t and it can’t.
Reseach on these levels started in Australia in 2005 under the VITAL programme. Since then programme has established what are known as ‘reference doses’ for all of the major allergens. Various European initiatives over the last 15 years, have replicated much of this research and there is now pretty general agreement on what thresholds could be safely enforced. The difficulty lies in translating that research into regulation – and sadly little progress appears to be being made on that front.
Farewell to ‘may contain’
Were such regulations to exist not only would the issue of whether a vegan manufacturer ‘intended’ there to be milk or eggs in their products be irrelevant but so would the dreaded ‘may contain’ precautionary labels which create so much frustation within the food allergic community.
Since ‘may contain’ gives you no reliable indication of whether or not the product does contain the allergen and if so, how much, every time a food allergic person is faced with a ‘may contain’ warning they have to:
- Be super cautious and not consume it just in case, even though the risk may actually be extremely low, thereby significantly reducing their food choice.
- Throw caution to the winds and eat it anyhow, possibly risking a serious, or even fatal, reaction.
- Spend long hours on the phone with the manufacturer trying to establish what the level of risk actually is.