Allergen Management from A to Z

"I'm glad that the excessive use of PAL (Precautionary Allergen Labelling) warnings is now recognized as a food safety issue," begins Marjan van Ravenhorst, owner of Allergenen Consultancy. "FNLI, CBL, NVWA, VWS, and patient organizations have effectively addressed this together. The new Dutch allergen policy mandates that every effort must be made to prevent cross-contamination, but if that's not entirely possible, a risk assessment must be conducted. We are moving from 'warning just to be safe' to 'you must not warn unless you can demonstrate that there is an actual risk.' This risk then needs to be substantiated." (For more on this, see the article 'New allergen policy, stricter regulations') 

Time to step up

"This calls for a shift in mindset within the food processing industry regarding the use of a PAL warning," Marjan anticipates. "For those already operating from a risk management perspective like VITAL, perhaps there will not change a lot. Although different reference values are used, and there is a greater emphasis on evidence. However, those not accustomed to a risk-based approach to cross-contamination of allergens need to step up: gather information from all suppliers, map out your processes, conduct cleaning validations, and so on."

The Excel-island culture

But she has a second concern: "When we read about product recalls related to allergens, the cause is often traced back to factors other than cross-contamination. This includes instances such as purchasing raw materials from alternate sources where the information differs, not adhering to recipes, labels not being updated with new information, or mix-ups—resulting in the wrong label being affixed to an otherwise correct product. These errors often arise because many companies still operate in what I would call an 'Excel-island culture.'"

"In my view, the focus in allergen management needs to be much broader," she concludes her argument. "Preventing cross-contamination is just one aspect. Additionally, there should be more internal focus on proper data management. Companies must understand that incorrect label or product information poses a food safety risk for individuals with food allergies. To manage this, not only the production process but also the entire data and allergen management system must be in order."

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