May Contain Traces of: Allergen Precautionary Statements and Allergen Management

Often, we see food products labeled with the statement, “May contain traces of…”.

What does this mean, really?

Let’s back up for a moment and talk about allergens. For people with food allergies, sensitivities or intolerances, avoiding specific foods and ingredients is an important health challenge. An allergic individual who comes into contact with an undeclared allergen may experience symptoms that can quickly progress from mild to severe, including anaphylactic shock and death.

By law, most prepackaged food products must be labeled and contain a list of ingredients (Food and Drug Regulations). Allergens are required to be declared either in the list of ingredients or in a “Contains (x)” statement following the ingredient list.

Manufacturers may also use a precautionary statement to warn consumers of possible allergens in the product. Examples of such statement are “May contain traces of peanuts and tree nuts”, and “Produced in a facility that also processes milk products”.

As a consumer, you can imagine that these statements are confusing and not easy to understand, and it seems that many food products have a precautionary allergen statement. Yet at the same time, the Canadian Food Inspection Agency cites undeclared allergens as the #1 reason for food recalls.

In 2012, new allergen labeling regulations came into force in Canada. The goals of these regulations were to (1) minimize risk for those with food allergies and (2) maximize choice of safe and nutritious food for those with food allergies.

Included in these regulations is clear direction on the use of precautionary statements. Only one precautionary statement is recommended, “May contain (x)”, where x is the name by which the allergen is commonly known.

In the exact words of Health Canada,

Precautionary labelling should only be used when, despite all reasonable measures, the inadvertent presence of allergens in food is unavoidable.

  • If the allergen is an ingredient or component of an ingredient of the food, it must be declared in the list of ingredients or in a “Contains” statement following the list of ingredient. It is not appropriate to declare the allergen in a “May contain (x)” statement.
  • If inadvertent cross-contact can occur because of shared processing lines or equipment, then a precautionary statement is appropriate.
  • If allergens are handled in a facility, and despite all reasonable precautions, cross-contact can occur, then a precautionary statement is appropriate.

Let’s talk about this last point a bit more. So say you make a variety of products in your facility, and you take no measures to control allergens in your facility. Is this statement appropriate? The answer is yes, but let’s be clear: a precautionary statement doesn’t replace proper allergen management.

Here’s an example of why. Say you manufacture beef patties, chicken burgers and vegetarian nut-based burgers, and the same piece of equipment is used for all three products. You include a precautionary statement on the label of the beef patties and chicken burgers that states, “May contain tree nuts”. After all, you would not want someone who is allergic to tree nuts to consume the product and have an allergic reaction. But what if an allergic individual eats the beef patties or chicken burgers, and gets sick anyways?   Generally, one does not expect that beef patties or chicken burgers would contain tree nuts.  Sure, you have been diligent to declare that tree nuts may be present in the beef patties, but could this have been prevented with proper allergen management? The answer is yes.

Here are 10 simple tips to help you manage allergens:

  1. Make a list of what allergens you handle in your facility. Refer to the CFIA’s list of priority allergens – list the allergens handled in your facility and in which products they are used.
  2. Assess your ingredients and suppliers, understand how and if they manage allergens, what allergens are in the products, in their facility and used in the same processing line or equipment.
  3. Ensure adequate allergen segregation in storage. Do not store allergens above non-allergenic ingredients, and ensure all ingredients are adequately protected from contamination. Use dedicated scoops.
  4. Map the flow of allergens through your facility. Identify the points and locations where cross-contact can occur.
  5. Schedule production to ensure segregation of allergens is maintained. Clean and sanitize between batches to prevent cross-contact. If you do not have dedicated equipment and make one batch of product after another, prepare the product with the allergen(s) last. But, if the batches contain different allergens, sanitizing your equipment between batches is necessary.
  6. Know which allergens come into contact with which equipment. Use dedicated equipment and tools, and make sure they are clearly labeled and segregated in sanitation and storage.
  7. Clean and sanitize food contact equipment, tools and utensils after each batch or production shift, and inspect before use.
  8. Where appropriate, use allergen test kits to verify sanitation.
  9. Ensure that your ingredients, rework and work-in-process are all traceable, labeled and managed to prevent contamination.
  10. Ensure all allergens are properly declared on product labels.

In conclusion, good management of allergens is the key to prevention. If you handle allergens in your facility and inadvertent cross-contact can occur (i.e. you’ve done everything humanly possible to prevent cross-contact but it is still likely), label your products appropriately with a May contain (x) statement.

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