For the last few years, PAL (precautionary allergen labelling) has been a hot topic in the allergy community. Sometimes because the labelling is daft (‘may contain’ on every product going, including water), sometimes because it’s unhelpful (‘may contain’ covering all allergens, or just ‘allergens’). There has been no legislation around what PAL should be and, in light of the confusion, the Food Standards Agency has decided to consult with the public and businesses in order to help frame potential legislation.
I’m in no doubt it’s needed – PAL can’t just be a meaningless catch all. We need clear understanding of how the risk of cross-contamination has come about. It may be that production lines are used for multiple products, some with one of the top 14 allergens, but are cleaned between product runs. It may simply be that an allergen in handled in the factory on another line. Most allergy sufferers recognise that there is risk if an allergen is in the factory; however, many need the information about the level of risk so they can make a proper assessment.
The Food Standards Agency is also considering including allergen labelling into the Food Safety Management System because:
There is a lack of standards for the risk analysis of allergen cross-contamination within food supply chains. Recent research for the FSA found that food businesses take very different approaches to assess and control risk before applying precautionary allergen labelling, and that standardisation around the application of precautionary allergen labelling is needed.
Personally, I welcome incorporating risk assessment for allergens into the Food Safety Management System, rather than creating a separate process.
Too many manufacturers have just slapped lazy labels on products to ‘cover every eventuality’. The current system has failed allergy sufferers and needs to be standardised so that labels are meaningful.
The consultation also looks at restaurants and how they communicate risks of cross-contamination on premises. This includes storage of utensils, storage of ingredients, and training levels. If allergens are handled properly, then this addition to the FSMS won’t be too onerous. By making it part of the FSMS is delivers a key message – handling allergens is part of food safety, not an added extra, or a fringe benefit. It’s a core skill for businesses to be able to manage this issue.
I really hope that the catering industry engages positively with this initiative, and that those restaurants issuing allergy waivers have a rethink about how they engage with allergic customers. If more and more restaurants issue waivers then I expect the next topic for legislation will be banning waivers. Its seems a shame that voluntary agreements aren’t strong enough to protect those with dietary needs, especially as allergies are a growing issue and dietary restrictions aren’t going away.
If you’re interested in having your say – here’s the link
https://www.food.gov.uk/document/precautionary-allergen-labelling-pal-consultation-pack
