‘May contain’ – have your say

Very good news – the Food Standards Agency have cleared their desks and are tackling the horribly unsatisfactory mess that is Precautionary Allergen Labelling, better known as ‘may contain’ warnings.

PALs have been the bugbear not only of the allergic consumer but of the freefrom industry for years. They are intended to warn the allergic consumer that the food they are about to buy/consume might have been contaminated with their allergen and therefore might not be safe for them to eat. An excellent idea but – there are major problems with its implementation:

1. What does ‘contamination’ mean? How grave is the risk?If all risk assessment is done properly and all allergen control protocols are followed strictly then there should be very little risk of cross contamination. But risk varies with the foods being manufactured so each situation has to be assessed individually.
   • The likelihood of a ‘milk free’ chocolate being contaminated with milk proteins if it is made on machinery that is also used for milk chocolate is very high as chocolate is incredibly sticky so it is almost impossible to clean that machinery to eliminate all milk proteins.
   • Where sesame seeds are used in a bakery, because they are so light and so small, it is all but impossible to eliminate the chance of them migrating into a sesame free product.
   • If peanuts or milk products are used at one end of a factory and peanut free/milk free products are manufucatured at the other end both using their own dedicatad machinery, the chances of cross contamination are extremely small.
   • But there is no way of telling from a ‘may contain’ warning which of these situations the warning refers to. Moreover, there is no way of knowing how diligent the manufacturer concerned has been about allergen contamination and therefore how ‘trustworthy’ a warning might be.
2. The scheme is voluntary as is the terminology used.This means that there are no ‘rules’ for anyone to work to, only guidelines – and there are no guarantees that the  guidelines that do exist are being followed. So –
   1. One manufacturer may be over cautious and insist on may contain warnings when the risk is minimal (as in the third example above) while another may decide not to put a warning on at all even though the risk could be significant.
   2. Since there is no set form of words, a huge range of terms are used many of which either really convey nothing or, in their desire to be helpful, convey far too much and are more confusing than they are informative.

As a result….

Allergic consumers do not trust any warnings (unless they  already know the manufacturer and have reassured themselves that their food is safe). This is not only frustrating but dangerous as either:

• the allergic consumer restricts their diet unnecessarily because they do not trust foods which actually are trustworthy but cannot convey that message
• they ignore all ‘may contain’ warnings thereby putting themselves at risk from foods which genuinely could be contaminated
• their fall back position being that they have to contact each manufacturer individually to make their own assessemnt of how trustworthy their warnings may be – time wasteful, annoying and frustrating as it is often hard to get answers.

These are not easy problems to solve – which is why the regulators have ducked the issue for so long – and why it is so good to see the FSA finally trying to come to grips with it. And come to grips with it from the grass roots up – by asking allergic consumers and the makers of free from foods exactly how they would like to see the situation resolved.

Please get involved…

So, please, everyone who has any interest in/experience of making, buying or consuming ‘freefrom’ food, take half a hour to read the really excellent consultation pack and take part in the consultation. You will find:

• The introduction to the project here – from which you can also find links to:
• The very helpful Consultation pack here
• The consultation itself here
• Plus various other background documents that you might find helpful.

The consultation is open until 14th March – but why not use those dog days between Christmas and New Year when, this year at least, there is little chance of you jetting off for a quick dose of sun, to make your views known.