The frustrations of shopping for the super sensitive

A few days ago we got an email from the mother of super-allergic little boy. She was furious and frustrated by the fact that every delicious looking freefrom food that she found on the FFFood Awards website was effectively barred to her because, although it was being sold as ‘freefrom’ it still carried warnings that it might contain ‘traces of dairy, wheat, gluten, soya etc’. Why can ‘freefrom’ not mean what it says, she wanted to know – that the product is totally free of the allergen?

As anyone who has been following either the Alpro saga or the more recent Tesco nut-warning campaign must be aware, most of those with potentially fatal allergies (or with children with potentially fatal allergies) will not take the unquantifiable risk that a ‘may contain’ warning presents as they simply do not know how great that risk may be. Understandably, they are infuriated by manufacturers who they believe are merely ‘covering their backs’ by slapping on ‘may contain’ warnings instead of genuinely ensuring that the products are totally ‘freefrom’ that allergen.

Similarly, they are infuriated by manufacturers who do not give the derivation of all of the ingredients in their products. If a glucose syrup is derived from wheat, why do they not say so?

While I totally sympathise with their situation, and there certainly are manufacturers who ‘hide’ behind ‘may contain’ warnings and poor labelling, labelling ‘freefrom’ food is not as simple as it seems. So, at the risk of bringing down the wrath of the allergy sufferers on my head as well, this is what I replied to her:

The following will not help you at all in practical terms – but it may help to explain why the situation seems so confusing and why even the best intentioned manufacturers rarely get it right. And why customer service departments are nearly always completely and rage-makingly useless! They simply have no idea of what is involved!

So we are dealing with two issues:

Contamination/’may contain’

The difficulty about contamination risk is that, to be able to guarantee that a product genuinely will not have any traces, no matter how minute, of the allergen in question, it really needs to be made in a dedicated factory into which that allergen never comes. Moreover, the manufacturer needs to have guarantees from all of their suppliers that the ingredients have also been made/grown/milled in a dedicated environment. There are really very few such facilities around as it involves, effectively, building a new factory to achieve this kind of separation. A greater expense than most manufactures can afford on the basis of the amount of the allergen-free food that they will sell.

There is an argument that if proper risk assessment is performed and proper allergen control measures put in place, the contamination risk when you manufacture allergen-containing food in the same facility as allergen-free food is, in reality, vanishingly small. Any allergen residues should be far below the level (20 parts per million for gluten for example) that is deemed to be ‘safe’ and so the product could rightly be declared to be ‘free’ of that allergen. In which case there should be no need for ‘may contain’ warnings which should only be triggered, if you follow the Food Standards Agency guidelines, when there is a ‘demonstrable and significant risk of allergen cross-contamination’.

Two problems….

One is that right now the only ‘allergen’ for which a ‘safe’ limit has been set is gluten – at 20ppm. The grand European plan is that over the next five years, levels will be set for all of the major allergens so, as with gluten, if a food tests at lower than the ‘safe’ level for dairy or nuts or whatever the allergen is, it can be declared ‘dairy free’ or ‘nut free’ and would not need to carry any ‘may contain’ warnings. But until these levels are set, no one knows what ‘safe’ levels are for the other allergens.

So, for manufacturers using shared facilities, what are they to do? They can test for other allergens (dairy, nuts etc) but there is currently no level below which the food can be declared to be ‘safe’, and it is impossible to test to absolute zero. So, do they ‘play safe’ by telling customers that it has been manufactured on a shared line and that therefore there is a very tiny possibility of allergen contamination – or do they put their faith in their cleaning procedures and, even though the product has been made on a shared line, claim that it is totally free of that allergen?

The second is that the setting of ‘safe’ levels for allergens other than gluten will not entirely resolve the issue. Just as there remain coeliacs who react to levels of gluten lower than 20ppm there will always be allergy sufferers so sensitive that they will react to lower levels – but there will be very few of them.

From a government/regulator’s point of view, they need to set up some framework that will work for the vast majority. So they will go with what the medical scientists have decided is a ‘safe’ level (eg a level below which 99% of the allergic population will not react) with the proviso that the tiny minority who are super sensitive (but, hopefully, know that they are super sensitive) will not be able to rely on those levels.

Transparency

Your other, equally understandable, gripe is about transparency – what is derived from what. There is really no reason why derivations should not be declared (eg glucose syrup derived from wheat), but, again this is not quite as simple as it looks.

It is the protein in an allergen that causes the allergic reaction. But some processes denature the protein in the ingredient to such an extent that, in theory, it no longer exists so can no longer cause an allergic reaction. This is the case with something like glucose syrups (made from wheat) or with distilled spirits (from barley), in neither of which the protein remains in a recognisable form so should not cause a reaction. In which case, why bother labelling it….

The problem is that, as with the ‘safe’ contamination levels, even though for the vast majority of allergic people the denatured proteins do not cause a problem, for the super sensitive they sometimes do.

However in this case there is no reason, beyond space on the label, manufacturers should not give the derivation of the ingredients, even if it is irrelevant for most people – even if, as you suggest, they only do so on their websites.

So, the bottom line is, I am afraid, that if you or your family are super sensitive, then shopping is probably always going to be a laborious pain. Even when the new ‘action levels’ come into force, and assuming that all manufacturers use them properly, you will still need to delve further into the manufacturing process to make sure that, for you, it will be safe enough to be acceptable. Sorry, but realistically, I think that is the way that it is….

Comments

Ruth Holroyd

27/04/2014 at 09:08

I hate to add another response she will not like, I have resorted to a pretty much totally processed free food diet to avoid this very problem and also mainly as I still have problems with most packaged foods at the moment. So sensitive in many ways ;o) Buy fresh fruit, veg, meat and fish and eat a healthy diet. Forget the FreeFrom foods – although there are few doing totally freefrom very well they are in the minority.
Michelle

27/04/2014 at 10:18

I am afraid that you are right, Ruth – the safest, and probably least frustrating, way to go is just to accept that you cannot buy anything pre-prepared and you will have to cook from scratch. Not, actually, nearly as much of a sweat as you anticipate once you get down to it. What is wrong with meat and two veg?….

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