What does this mean to the food industry? Check your Allergen Control Program Allergen-related issues have become a major concern for both regulators and public health. Insurance claims for food-allergy anaphylactic reactions have risen an average of nearly 400% over the last decade, with peanuts and tree nuts/seeds soaring beyond that to 445% and 603% respectively. Experts cited in the report Food Allergies: A Growing Health Concern by FAIR Health, Inc., suggest that the rise could be attributed to increasing antibiotic use, C-sections (affecting the baby’s microbiomes) and sterile environments, along with healthcare provider advice to avoid feeding babies allergenic foods. While food production cross-contact or labeling errors are not mentioned in this report, one simply needs to read between the lines to know that an increasing number of allergic reactions and/or food-allergic consumers equates to an increased potential for consumer reaction and product recall when errors are made on the plant floor – or anywhere along the food supply chain. And while food producers’ preventive controls for allergen contamination should be at the highest possible level regardless of the number of food-allergic consumers, it is simply common sense that an increase in insurance claims could lead to an increase in claims against a manufacturer if the issue is traced back to an unlabeled allergen. As likely expected, peanuts and tree nuts/seeds were among the highest causes of anaphylactic reaction – combining to total 44% of all such insurance claims. However, this does not take non-nut producers off the hook, as another 33% were attributed to “other specific foods” – the diagnosis code listed by physicians when the precise food that caused an anaphylactic food reaction is not known. Interestingly, not all of the Big 8 were listed as top causes, with wheat and soybean not mentioned in the report. The other four were listed (eggs, 7%; crustaceans 6%; milk 5%; fish 2%), but the list also included fruits/vegetables (2%) and food additives (1%) – making it critical that food producers ensure that all ingredients are listed on the label. Otherwise, in this day of rampant litigation, the non-labeled addition of ingredients such as pineapple or celery could come back to haunt you. On the other hand, the report affirms the common belief that younger children are most affected, with claims for babies and toddlers (age 0-3) making up the greatest percentage (27%); children (aged 4-10) coming in second at 24%; and the rates gradually declining thereafter. But, while some people may outgrow food allergies, and/or simply become more adept at managing them, there were still a significant number of claims for older adults, with those over 30 making up 25% of all claims – some of whom were not diagnosed until adulthood. If we were to assume that the majority of the other food-allergic adults had learned to manage their allergy, then we can also assume that a significant number of those reactions is likely due to cross contact and unlabeled allergens. Also cited in the report was Food Allergy Research & Education (FARE) CEO/CMO James Baker, who noted that the group’s own information suggests that it is not just the frequency of allergic reactions that is increasing but also the severity of food allergy in individuals. As some FARE statistics show, childhood hospitalizations for food allergy tripled between the late 1990s and the mid-2000s, with about 40 percent of children with food allergies having experienced a severe allergic reaction such as anaphylaxis. Additionally, FARE facts state that most fatal food allergy reactions are triggered by food consumed outside the home – bringing us back to the assumption that the food was not labeled or stated as having an allergen – whether at retail, foodservice, or “potluck” event. The FAIR Health report also unearthed some surprising statistics, such as the 110% increase in claims from those in rural areas vs. 70% increase in urban areas. As such, the group plans to release a white paper in October which digs deeper into this data along with other factors such as geography, gender, and costs of services. We will keep an eye out for this report to bring you any updates that could impact you. So of course, we need to ask what does this mean for the food industry? In simple terms, it means take a look at your allergen controls to make sure they are solid. This includes what you are doing internally to control allergen risks as well as supply chain and labeling. The message is just as important at retail and food service as it is with manufacturers. This type of report is what puts pressure on the regulators to control risks, and we have certainly seen very large recalls recently from peanuts unexpectedly being in products such as cumin and flour. FSMA GMPs have focused more on allergens and so should everyone in the food industry because, most certainly, the regulators will continue to give allergen control a high level of attention. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
