In early 2022, EFA participated in a consultation for a revised European Commission notice on the implementation of Good Hygiene Practices (GHPs) in food management. The notice is linked to Regulation 852/2004/EC on the hygiene of foodstuffs and it is of particular interest for people with food allergy.
Generally, Commission notices serve as guidance with regards to specific and/or technical aspects of a given legal framework. This notice outlines specific measures at different food production stages, with the aim to prevent cross-contamination with allergens. They are not legally binding, but rather aim to facilitate and harmonise the implementation of EU legislation.
Among the EFA input that was taken up by the Commission, our proposals on quantitative risk assessment, allergen training and Precautionary Allergen Labelling (PAL) stand out.
Quantitative Risk Assessments and allergen management training urgently needed
In our response to the Commission consultation, EFA highlighted the life-threatening risks of allergen cross-contamination for people with food allergies. Allergen management must be a cornerstone of all food safety systems, including procedures that prevent cross-contamination across the food production cycle.
More particularly, EFA is glad that the Commission agrees with several of our proposals, including the need to add a requirement for raw materials suppliers to provide quantification in case of unintended allergen presence. This enables the manufacturer to conduct risk assessment later on.
With regards to food processing during later production, the notice underlines the importance of specific training for workers, for example when handling products potentially containing allergens and others that do not. In cases when wet cleaning is used, it is suggested that the cleaning water be analysed for allergen residues.
Precautionary Allergen Labelling to be put on a solid basis
Turning to labelling aspects, EFA stressed that unintended allergen presence is not merely a sanitation issue during manufacturing, but rather part of a whole allergen management system 'from farm to fork'. Therefore, it is important that the Commission notice is not interpreted in a way that proper cleaning by the operator eliminates the risk of cross-contamination. Precautionary Allergen Labelling (PAL) might still be needed, subject to a thorough quantitative risk assessment.
To facilitate the implementation of PAL, a holistic allergen management framework must include harmonised reference doses/action levels for unintended allergen presence, enabling food manufacturers as well as food inspection authorities to validate food production and food products.
The notice stresses that Precautionary Allergen Labelling must be based on an ‘appropriate’ risk assessment (without specifying, though, that it must be quantitative), for which responsible is the food manufacturer.
You can access the adopted Commission notice here.
You can access here EFA’s input to the consultation, in bold-highlighted text and comments.