After you have assessed the risk of cross contact with allergens, and where possible eliminated or reduced the risk, you need to decide whether or not precautionary labelling is appropriate.
Allergic consumers need ingredient information, which is easy to find, read and understand. Any allergen cross-contact, which has proved impossible to control, should be made clear.
You should only use precautionary labelling (including ‘may contain’ statements) where there is a demonstrable and significant risk of allergen cross-contact. You should never use precautionary labelling as a substitute for good manufacturing practice.
Several national guidelines provide detailed advice on how you can communicate the allergen risk to you consumers by the product label.
Most recommend to use simple phrases such as ‘May contain X’ or ‘May be present: X’ for precautionary labelling.
Guidance notes for consumer careline staff
In addition to communicating with your consumers via the label you may choose to provide additional information via a consumer careline. You are welcome to print out and use the pdf file:
Consumers at risk from severe food allergies need to avoid these foods, often even if present in trace quantities. Even accidental trace cross contact may cause them to suffer a severe or life-threatening allergic reaction.
It is very important that they know exactly what is in the food they eat. Many know that they should not eat out in restaurants or from takeaways. Instead they look to factory produced foods, and in particular meal solutions, ready to eat and home baking ideas.
It is likely that a food manufacturers care line staff will receive enquiries from a consumer:
- Whose child may have had an allergic reaction and suspects that your product may have caused it.
- Who has eaten your product and believes that it may have triggered allergic symptoms.
- Who has tasted or smelt what they think may be an allergen and wants to know more about the product.
- Who is looking for a product which is free from a particular allergen, or even a list of products which are ‘free from’ a known allergen.
If you receive the first or second types of enquiry, please check that the person is no longer at any immediate risk and has received medical attention, where appropriate.
You should record all available information about the product including bar codes, when and where bought, batch numbers and use by dates. It is important to know whether it is a multipack. You should also ask the consumer if they have any of the suspect food left over and, if appropriate, offer to have it analysed.
You should also try to obtain information about the circumstances under which the product was eaten (alone or with other foods), the symptoms observed, including their timing, and the treatment administered.
If you take the name and number of the consumer, you can get back to them as soon as possible. If they are seriously concerned, they won’t mind.
The information you give them must be accurate and consistent across your business. You should be particularly clear whether the allergen is a deliberate ingredient or present because of cross contact.
Consumers get very upset when one member of staff tells them something, which is then contradicted by another. Ideally, you should check as far back up the food supply chain as you can, and then agree with another colleague what the answer is. You should record what you have said.
It is very important for allergic consumers to be able to FIND, READ and BELIEVE all ingredients and allergen cross contact information. Could they be caught out by your products? What could you do to reduce this risk?
This information is modified from a document prepared by Allergy Action and can be copied freely to help save lives.