Jun 22nd, 2022
5 mins

Members will be aware of the FSA’s ongoing investigations into peanut contamination of soya lecithin produced in India.

To reiterate, as outlined in the FSA’s statement on 25th May, there is currently no evidence of unsafe food having been placed on the market and information provided by industry to date suggests that the incident has been controlled.

As investigations indicated a wide distribution, with many businesses affected across the UK and globally, the FSA decided that the most effective way of addressing the issue was to provide industry with guidance and to make consumers aware of the issue.

The industry guidance asked each business to carry out its own risk assessment to ensure that only safe food is placed on the market. However, following conversations with members, it’s clear that a few ‘pointers’ would be welcomed.

Please note that the following is not an exhaustive list and does not constitute formal advice or instruction but merely gives suggestions of things to consider:

  • First and foremost, remember you need to ensure the food you sell is safe. Therefore, any food placed on the market or supplied needs to be risk-assessed to decide whether a recall/withdrawal is necessary to protect consumers.
  • The risk assessment should be based on worst case scenario and look at the whole process.
  • It is reasonable to expect that an effective positive release system is put in place at the raw material stage.
  • The contamination levels may be below limit of detection for the chosen laboratory test method, therefore a calculation will be necessary.
  • In your calculations, use the highest level of peanut protein that has been detected in the raw material. Also, consider mixing bowl tolerances – look at the highest potential inclusion levels of the affected ingredient(s)/components in combination with the lowest inclusion levels of non-affected ingredients/components.
  • Consider the amount per unit of consumption and how much may be realistically consumed, even in excess.
  • The Voluntary Incidental Trace Allergen Labelling (VITAL) Program is widely used as a useful tool to provide a risk-based methodology for food manufacturers to use in assessing the impact of allergen cross contact and to provide appropriate precautionary allergen labelling (PAL).
  • If the result of your calculation is remotely near the VITAL threshold, we would recommend seeking expert opinion for confirmation. It may be that the quantity of product needed to be consumed to invoke a reaction is so huge that the food would not necessarily be considered unsafe and so a withdrawal or recall may be unnecessary.



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