FOOD ALLERGEN MANAGEMENT TOOLKIT
Canadian Spice Association AGM
May 6, 2016 Presented by
Tiina Henkusens Anthony Gene Andrew Sweet
FOOD ALLERGEN MANAGEMENT TOOLKIT Canadian Spice Association AGM - - PowerPoint PPT Presentation
FOOD ALLERGEN MANAGEMENT TOOLKIT Canadian Spice Association AGM May 6, 2016 Presented by Tiina Henkusens Anthony Gene Andrew Sweet Agenda Allergen Labelling & Allergen Management Resources Allergen Control Program
Canadian Spice Association AGM
May 6, 2016 Presented by
Tiina Henkusens Anthony Gene Andrew Sweet
Agenda
Allergen Labelling & Allergen Management Resources Allergen Control Program Analytical Services
Changing Regulatory Environment
regulations came into force August 4, 2012
enhanced surveillance initiative, targeted surveys were used by CFIA between 2010 – 2012 to evaluate various foods for specific hazards
exports & domestic production with CFIA modernization & Safe Foods for Canadians Act/Regulations
International Food Allergens
Source: http://farrp.unl.edu/f0c3a875- ce07-404f-b05f-8a7983e57daa.pdf
vary by region
according to the receiving country’s requirements
Health Canada – Allergen Labelling
Health Canada's Amendments to the Food Allergen Labelling Regulations Health Canada's Position on Highly Refined Oils Derived from Food Allergen Sources Mustard: A Priority Food Allergen in Canada - A Systematic Review
Health Canada – Precautionary Allergen Statements
Health Canada's policy for enhancing the protection of food-allergic consumers in Canada is
based on two guiding principles:
Precautionary labelling should only be used when, despite all reasonable measures, the inadvertent
presence of allergens in food is unavoidable
It must not be used when an allergen or allergen-containing ingredient is deliberately added to a
food or when there is no real risk of an allergen being present in the food
"may contain [X]”, where X is the name by which the allergen is commonly known http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/precaution_label-etiquette-eng.php
CFIA – HACCP Generic Model for Spices
In an effort to help reduce the risk
associated with spices and assist manufacturers that wish to adopt a Hazard Analysis Critical Control Point (HACCP) approach, CFIA has developed the Food Safety Practices Guidance for Spice Manufacturers document
Applies to Div 7 spices
http://www.inspection.gc.ca/food/safe-food-production-systems/haccp-generic-models-and-guidance- documents/guidance-spices/eng/1366340448103/1366340494598?chap=0#c1 Example,
Health Canada / CFIA - Gluten Free
A gluten-free claim is any representation in labelling or advertising that states, suggests or
implies that a food is gluten-free, as per B.24.018 of the Food and Drug Regulations (FDR)
Foods containing gluten as a result of intentional addition may not be represented as being
gluten-free. However, if a manufacturer using a cereal-derived ingredient includes additional processing steps which are demonstrated to be effective in removing gluten, the food may be represented as gluten-free.
Any gluten that is present due to cross-contamination in a food labelled gluten-free should be
as low as reasonably achievable and must not surpass 20 ppm of gluten, a level that is considered protective for the majority of people with Celiac disease
Health Canada / CFIA - Gluten Free
In instances where the gluten is present due to cross-contamination at a level of less than
20 ppm in the food, the CFIA will follow up with the manufacturer or importer regarding the presence of gluten in the product. These manufacturers and importers should have good manufacturing/importing practices (GMP/GIP) in place to achieve the lowest levels
position, enforcement action on products containing less than 20 ppm gluten as a result
the gluten-free claim
In all instances, regardless of source, if more than 20 ppm of gluten is present in a food
labelled as gluten-free, the product may be in violation of the FDR Section B.24.018 and/or Section 5.1 of the Food and Drugs Act (FDA) and, on the basis of a health risk assessment provided by Health Canada, subject to appropriate enforcement action by the CFIA, which may include the possibility of recall
http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/allergens-and-
gluten/eng/1388152325341/1388152326591?chap=2
http://www.hc-sc.gc.ca/fn-an/securit/allerg/cel-coe/avoine-gluten-oats-eng.php
Allergen-Free Claims
General claims stating only "Allergen Free" or "No Allergens" are considered to be too broad in
nature and are therefore not acceptable. The list of potential food allergen sources is not restricted to the list of priority food allergens identified by Health Canada.
There are over 200 food proteins that can cause adverse reactions to some segments of the
free of allergens
http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/allergens-and-
gluten/eng/1388152325341/1388152326591?chap=0
CFIA Targeted Surveys – Ground Spices
As part of the 2007 Food Safety Action Plan enhanced surveillance
initiative, targeted surveys were used by CFIA to evaluate various foods for specific hazards
In 2010-11, a total of 268 ground spices were analysed for the
presence of gluten
Gluten is not permitted in single pre-packaged ground spices. It is
therefore expected that single ground spices do not contain gluten; the unexpected presence of gluten may pose a health risk for sensitive individuals
http://www.inspection.gc.ca/about-the-cfia/newsroom/news-
releases/2012-08-15/eng/1344951042395/1344951257435
CFIA Targeted Surveys – Ground Spices
Of the 268 samples, 63 samples (24%) contained detectable levels
A number of factors are considered when determining if a food
poses a health risk. The amount of the hazard, in this case gluten, that a person would ingest during a typical meal is a primary
small at approximately 0.5 g.
It was determined, in consultation with Health Canada, that 62
(97%) of the spices with detectable levels of gluten did not pose a risk to sensitive individuals. One sample of mace was determined to be in violation of the FDA and FDR. This product was recalled.
CFIA Targeted Surveys – Flavour Packets
bake mixes, dessert mixes, sauce mixes, powdered drink mixes, seasonings, spices mixes and soup bases
undeclared allergens from the survey may be considered to be in violation of Section 5(1) of the Food and Drugs Act if allergens are added and not declared.
http://www.inspection.gc.ca/food/labelling/foo d-labelling-for-industry/list-of-ingredients- and-allergens/industry-notice-2013-07- 08/eng/1373289087016/1426168102706 2010-2011 Survey Results for Gluten
Additional Resources
ASTA Food Allergy Research and Resource Program (FARRP)
Goodman and Philip Johnson serve as faculty members in the Department
Food Allergy Canada
A requirement for any GFSI Programs Points for Consideration:
Ingredient Cycle throughout the supply chain Product Cycle within the process Programs for claims, such as, Gluten free status
Process Review for claims:
How are Raw Materials verified Implementation of a risked base testing program or assessment steps on raw materials Risk assessment for cross contamination Validation data for the process and the product
Validation data for the process available for review Employee knowledge:
At the plant level T echnical team
Tools utilized to communicate allergens across all levels Ingredient storage
Establish clear and accurate company policy on allergen labelling Develop communication strategies with service team:
How to answer questions on food allergies efficiently Provide regularly updated information
Keep communication simple and clear:
Written, labelling, consumer services, Websites, etc.
Refer consumers to organizations for people with food allergies
May 3, 2016 Presented by Andrew Sweet
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May 3, 2016
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May 3, 2016
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May 3, 2016
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May 3, 2016
Market leader in Allergen diagnostic kits – Peanut, R5 Gluten, Milk, Soy, Almond, Egg, other. Has received some recognition with Health Canada and CFIA. Have products applicable for in-plant detection and Laboratory Detection (lower sensitivity, greater specificity) Growing reputation for Peanut and Gluten testing. Have Health Canada approval for Hazelnut. While less recognized from a regulatory standpoint they are growing in popularity. Kits are more user friendly and cater to the in-plant testing market.
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May 3, 2016
NOTE – Not all kits report the same units!!! 4 ug/g of Peanut 1 ug/g of Peanut Protein
***Some kits report as ug/g of Peanut Protein and others as ug/g of Peanut. A peanut contains 25.8% of protien.
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In development:
Interesting Case Study:
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May 3, 2016
Food Recalls by Type - CFIA
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May 3, 2016
Food Recalls by Allergen - CFIA Spices & condiments segment - ~17% and ~16% of all recalls in 2014 and 2013 resp.
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Key Takeaways…
Food allergen recalls have increased Know the risks related to your product, facility & supply chain Understand the food allergen regulations & policies A gluten-free claim provides a competitive advantage and may
require a targeted approach for claim validation
Spices are complex. Be well informed of the science including
available analytical methods
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