Food allergen management: What you need to know about the Codex code of practice

Food allergen management: What you need to know about the Codex code of practice

9 May 2021 | Christopher James, Food Safety Specialist - Allergens | Helen Arrowsmith, Principal Food Law Adviser & Allergen Specialist | Anton Alldrick, Special Projects Manager

Roughly 3% to 10% of adults and 8% of children worldwide are estimated to have a food allergy. Cases of food-induced anaphylaxis, at times resulting in fatalities, highlight the importance of allergen management in the food and drink industry – making this not only a current hot topic, but also one that the sector will continue to deal with long term.

Codex recently shone light in this area following publication of its code of practice (COP). As this significant guideline generates traction, our food safety and regulatory allergen specialists breakdown the key parts to help you understanding the COP that can assist with your allergen management.

Codex on food allergen management for food business operators

The Codex Alimentarius Commission (Codex), a collaboration between the Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO), is the global organisation that provides international food standards, guidance, and codes of practice. This is to help ensure that food is safe and can be traded around the globe. Along with the most recent revision to the Codex General Principles of Food Hygiene (amended in 2020), they published their first ever Code of Practice on Food Allergen Management for Food Business Operators.

Food allergens

Allergic reactions to food are the result of an adverse immune response to proteins within foods. The Codex COP tells us that consumption of food allergens should be identified as a significant food safety hazard for allergic individuals. Whist many different foods can cause allergic reactions, globally there are eight food product groups (including products derived from these), which cause the majority of allergic reactions, these are:

  • cereals containing gluten
  • peanuts
  • tree nuts
  • milk
  • eggs
  • fish
  • crustaceans
  • and soybeans

Providing accurate information to food-allergic consumers is critical to ensuring their safety. Different jurisdictions have different rules concerning the obligatory and accurate provision of information concerning foods which are considered to be significant food allergens for their population. Other food allergens such as sesame, mustard, molluscs, celery, and lupin are recognised as important in many countries, including the UK and Europe (for full list in these jurisdictions: Food Information to Consumers Regulation (EU) No.1169/2011 Annex II).

Testing can help prevent serious packaging malfunctions or an impact on the product’s quality, helping manufacturers avoid any unexpected financial burden or an impaired product.

It’s evident that inherent issues may arise when using metal packaging, which is why it’s important to ensure you’re exposing your new packaging to rigorous testing by experts - they’ll know of the potential issues that may arise and can assess accordingly. Testing can help prevent serious packaging malfunctions or an impact on the product’s quality, helping manufacturers avoid any unexpected financial burden or an impaired product.

Processing methods such as thermal or high-pressure processing, which are often used to control pathogenic microorganisms, generally do not destroy allergenic proteins. Thus, the management of food allergens is crucial to prevent the presence or introduction of undeclared and/or unintended allergens in food products, which results in the hazard of inadvertent consumption of a food allergen by a sensitive individual.

Pushing proactivity in allergen management

The guidance provided by Codex to FBOs is to adopt a proactive and preventative approach to managing allergens in the food chain, rather than a reactive response once an allergen issue (such as inadvertent cross-contact of a food with an allergenic food) has occurred. This can be achieved through good hygiene practices (GHPs) or pre-requisite programs and, where appropriate, the implementation of HACCP systems.

Food allergen management: What you need to know about the Codex code of practice - Image 1

Food allergen management: What you need to know about the Codex code of practice.

The Codex COP states that allergen management systems and their control measures should be based on risk assessment conducted by the FBO, in which they must identify the allergenic nature of the foods they handle and establish controls. This is to eliminate or minimise the potential for introduction of unintended allergens through cross-contact, or for undeclared allergens to be present due to errors in the supply chain. The provision of accurate allergen information for consumers of foods sold loose (for example in food service) and on labelling of prepacked foods is also emphasised as an objective of the allergen management plan.

Guidance and examples of good practice allergen management are provided in areas such as:

  • primary production
  • design and facilities
  • maintenance and sanitation
  • personal hygiene
  • transportation
  • product information, and
  • training.

The largest section of the COP relates to control of operation, which covers aspects such as control of food hazards, incoming material requirements, management and supervision, documentation and records, and recall procedures. Advice relevant to manufacturing and retail and food service is provided separately in each section.

Whilst the Codex COP is guidance, it does provide global regulators and legislators with the principles upon which to lay down new legislation or amend existing laws. This has already been observed with the publication of Commission Regulation (EU) 2021/382. This legislation is an amendment to the general hygiene Regulation (EC) 852/2004 in the EU to introduce requirements for FBOs to manage food allergens. In addition, in the US the Food Allergy Safety, Treatment, Education, and Research Act of 2021 (FASTER Act) has been passed to add sesame to the list of major allergens.

Once developed, existing food allergen management practices should be periodically reviewed. The Codex COP provides guidance on a proactive approach for effectively managing allergens in all food businesses from farm to fork and can therefore be used to help improve existing plans and develop them where they are currently limited or even absent. Better pre-emptive management of allergens and accurate allergen labelling will not only help to prevent potential financial implications (for example, from product recall or withdrawal) and brand damage for food businesses’, but will also benefit allergic consumers (by reducing their risk and uncertainty) ultimately improving their quality of life.

Need help with allergen management?

Our team of experts at Campden BRI have published guidelines to help the industry with some of the issues discussed in this article (Campden BRI members receive a discounted price):

Guideline 59: Validation of cleaning to remove food allergens
Guideline 71: Food allergens: practical risk analysis, testing and action levels

Christopher James

About Christopher James

Chris joined the Food Safety Management Systems (FSMS) team at Campden BRI in August 2019 after studying Nutrition at Coventry University graduating with a BSc (Hons). He is a Registered Associate Nutritionist (ANutr). Read more...

Helen Arrowsmith

About Helen Arrowsmith

Helen Arrowsmith is currently a Principal Food Law Adviser and Allergen Specialist in the Regulatory Affairs Department at Campden BRI. Helen uses her knowledge, gained over more than 17 years working with the food and drink industry, to provide advice on relevant UK and harmonised EU legislation, to present on training courses, and to contribute to publications such as Food Law Alert. Read more...

Anton Alldrick

About Anton Alldrick

Anton joined Campden BRI in 1990 and held a number of management positions before being appointed Special Projects Manager. He provides consultancy and project management services - particularly in the areas of chemical food safety and scientific regulatory affairs. Read more...

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