APAC allergen issues with Jasmine Lacis-Lee, President and Board Chair of the Allergen Bureau

With Food Standards Australia New Zealand reporting that the top reason for food recalls in the region being undeclared allergens caused by packaging errors, we sit down with the Allergen Bureau president to chat allergen management and accurate allergen labelling. 

A food microbiologist with over 25 years of industry experience, 16 years of those in various laboratory, management and quality roles in the food manufacturing industry, Jasmine Lacis-Lee is an expert in allergen management.  

She is also currently President and Board Chair of The Allergen Bureau, the peak industry body, representing best practice food allergen management, providing resources to support manufacturers in risk assessment, risk review, and food labelling. 

So, when Lacis-Lee talks about the steps businesses should be taking to keep consumers safe and informed about allergens, it’s safe to listen.  

Implementing an allergen management plan 

Lacis-Lee explains how the Allergen Bureau advises the food industry. “Our view is that all businesses should have a verified documented allergen management plan. We continue to advocate for a harmonised approach across the entire food industry to improve allergen control and food safety.” 

Lacis-Lee knows that the challenges associated with managing allergens are complex and often best tackled collectively rather than by any one single company. 

Our view is that all businesses should have a verified documented allergen management plan.

“That’s why at Allergen Bureau we are committed to fostering a collaborative, pre-competitive environment where industry stakeholders can come together to innovate and develop best practices that benefit everyone.” 

Around the globe high-profile cases are highlighting how allergy process failures are endangering consumers. Currently food allergies are less prevalent in APAC than in some other areas of the world. But it is still reckoned that 10% of children and 2-4% of adults suffer. So, businesses need to be vigilant in their approach to allergen food safety. 

The key industry guidance resources to follow 

The Allergen Bureau recommends three key industry guidance resources to assist with food allergen management, labelling, and identifying potential allergens in products. These are designed to help the food industry approach allergen management and labelling consistently and effectively and provide a foundation for every food producer to understand what they need to know about allergen management and labelling. 

Lacis-Lee says businesses should be reviewing raw material specifications thoroughly to ensure the information is accurate, have a HACCP-based Allergen Management Program, understand the potential sources of cross-contact allergens, and know how effective their program is in controlling those risks.

She explains that their three-step industry guidance recommends businesses use:

1. Food Industry Guide to Allergen Management and Labelling (FIGAML): for an overview of allergen management and labelling. FIGAML outlines industry best practices for managing allergens, labelling, and communication including the latest Plain English Allergen Labelling (PEAL) regulations for Australia and New Zealand.
   
   
2. Allergen Risk Review (ARRW): This interactive website offers detailed guidance on assessing allergen risk at every stage of the food production process. It helps determine whether cross-contact allergens are present, asks businesses how effective current controls are and helps businesses determine where to focus to lower the residual risk. 
   
   
3. VITAL® Program: The VITAL (Voluntary Incidental Trace Allergen Labelling) Program provides a standardised risk assessment process, used to underpin the use of Precautionary Allergen Labelling (PAL) statements. It helps food companies review the allergen status of ingredients and processing conditions that affect the final product, determine cross-contact levels and recommends labelling outcomes. The latest update, VITAL 4.0, was released on August 13, 2024.

“Through initiatives like our VITAL® Program and the recent launch of VITAL 4.0, which offers standardised allergen risk assessment tools, the Allergen Bureau is working to empower manufacturers to label their products more accurately, ensuring the safety of consumers with food allergy,” she adds.  

The role of undeclared allergens in food recalls 

The allergen issue is also affecting food recalls, with the Food Standards Australia New Zealand (FSANZ) recently reporting that the top reason for them in Australia is undeclared allergens caused by packaging errors. 

Three areas have been identified, which may lead to a recall due to a packaging error. These include: 

1. A lack of allergen labelling awareness by staff or the misinterpretation of standards. 
   
   
2. Errors that occur during packaging. For example, a product being packaged in the wrong packaging.
   
   
3. Label error - Examples include labelling errors resulting from the incorrect translation of ingredients, or ingredients being reformulated and the labelling not reflecting the change

Lacis-Lee knows how damaging errors in this area can be. “Recalls are a last resort in our food safety network and describing them as undesirable for both consumers and businesses is an understatement. The cost to any business can reach hundreds of thousands of dollars, with the potential damage to consumer confidence being even greater.” 

"Recalls are a last resort in our food safety network... The cost to any business can reach hundreds of thousands of dollars, with the potential damage to consumer confidence being even greater.” 

 

She notes that many of the recalls appear to be associated with products which also carry ‘free from’ claims such as “dairy free”. For these products a very high level of due diligence is required to ensure the claim is always valid. 

Why traceability is vital to allergen management 

A traceable food supply chain is crucial for effective allergen management, especially when it comes to free-from products. Lacis-Lee says, “Traceability allows food producers to accurately identify and manage allergen risks, particularly those that may be present due to cross-contact.” 

The Allergen Bureau’s Voluntary Incidental Trace Allergen Labelling (VITAL®) Program defines cross-contact as the unintentional incorporation of a trace amount of a food allergen into another food.  

Lacis Lee continues, “Cross-contact can occur for several reasons: 

• Agricultural co-mingling of raw materials, at paddock, harvest or transport 
  
  
• Carryover from an ingredient that contains cross-contact.
  
  
• Use of shared manufacturing equipment or concurrent production lines. 
  
  
• Equipment/ product design can create cleaning limitations.

“Identifying allergens in foods and ingredients requires thorough consultation with suppliers and detailed raw material specifications. By ensuring all allergens, including unexpected ones, are identified and included in the product risk assessment, the food industry can meet regulatory requirements, reduce the risk of allergen-related recalls, and provide essential information to consumers with food allergies.” 

“Identifying allergens in foods and ingredients requires thorough consultation with suppliers and detailed raw material specifications."

The impact of the new PEAL requirements 

The recent changes in food allergen legislation should also be having an impact in the industry. The Australia New Zealand Food Standards Code already requires that any major food allergens or their products must be labelled when present in a manufactured food as an ingredient, additive, processing aid, or as a component of one of these.  

“The new Plain English Allergen Labelling (PEAL) requirements, mandated on 25 February 2024, for Australia and New Zealand, specify that allergen information must be declared in a specific format and location on food labels, using simple, plain English terms, in bold font” explains Lacis-Lee. “These changes are designed to help consumers quickly and easily locate allergen information on food labels, enabling them to make safer food choices.” 

Many food manufacturers were already providing allergen information using the Allergen Bureau best practice labelling approach, which the PEAL legislation has used as a foundation, but this was applied on a voluntary basis.  

"[The Plain English Allergen Labelling (PEAL) requirements] are designed to help consumers quickly and easily locate allergen information on food labels, enabling them to make safer food choices.” 

“The new legislation aims to standardise the way in which allergens are labelled across the industry, both in packaged foods and food service. It has meant that all labels have been reviewed and changed, so there is no doubt that this will drive awareness of the importance of clear and consistent allergen information for consumers.” 

The best way to keep consumers safe 

Want to make sure your business is following all the most up-to-date guidelines?  

Lacis-Lee recommends conducting an allergen risk review. This systematic review of every step in the process can be done at the same time as a HACCP review (but taking time to specifically focus on where allergens are and how they are controlled) by a cross functional team of cleaners, engineers, production workers, management staff and senior leaders.  This process helps businesses consider risks and how effectively their allergen management programs (pre-requisites, procedures and HACCP controls) mitigate those risks. 

“The two work together as a feedback loop for each other,” she explains. “An allergen risk review starts with verifying the information in raw material specifications, so it also reduces the risk of overseas suppliers misunderstanding local laws.” 

The future of APAC allergen management  

To ensure that consumers with food allergy can eat confidently, allergen risk reviews and embedded allergen management practices are key. But there is a sticking point – overall consumer safety cannot be achieved if consumers ignore precautionary allergen labels. Stakeholder collaboration is critical to ensure each group in the food supply chain from food provider to consumer understands the eco-system.  

“An allergen risk review reduces the risk of overseas suppliers misunderstanding local laws.”

“That’s why the Food Allergen Management Consensus Statement was developed through industry stakeholder meetings,” says Lacis-Lee. “The statement recognises that food allergen management responsibilities are combined, and rely on the shared responsibility of the consumer, the packaged food industry and food service establishments.” 

So, what changes would the Allergen Bureau like to see the food industry adopt? 

“Looking ahead,” she says, “we are focused on advancing global harmonisation in allergen risk assessment and labelling. This means aligning practices across borders to ensure that, no matter where a product is produced or consumed, it meets the highest standards of safety for consumers with food allergy.” 

She also hopes education will play a key role in this effort, both within the industry and in broader public awareness, to ensure everyone understands the importance of rigorous allergen management and risk-based communication of cross contact allergens.  

“While our tools and resources will continue to evolve with the latest scientific developments, our core commitment remains the same: to drive industry-wide collaboration in a pre-competitive space. This approach allows us to collectively tackle challenges, create innovative solutions, and ultimately make the food supply safer for those with food allergies.” 

Recommended reading 

The comprehensive range of resources recommended by the Allergen Bureau aimed at helping manufacturers reduce the risk of recalls includes the Food Industry Guide to Allergen Management and Labelling (FIGAML), the Allergen Risk Review Website, the Unexpected Allergens in Foods Guide and Assessing Agricultural Cross-Contact Risks Guide. Additionally, they have a  free helpline available to the food industry for further assistance, and a detailed overview of recalls can help manufacturers stay informed and proactive as outlined in this detailed summary. 

For more information on the responsibilities of all stakeholders in relation to allergen management, please visit the Allergen Management Consensus Statement developed jointly with ASCIA, Allergy & Anaphylaxis Australia, Allergy New Zealand, National Allergy Council, and the Centre for Food and Allergy Resource. 

This statement is currently under review to include PAL and additionally recognises the importance that health professionals, retailers, and regulatory and enforcement agencies must provide safe food choices to consumers with food allergy.  

Allergen awareness and control are big topics in the food sector. If you'd like to read more on the subject check out our blog series on the subject here.

Want to dig deeper into the upcoming regulations shaping the food industry's traceability journey? Then check out our new report on the subject. Download your copy to get all the insights.