An allergen threshold of 0.5mg per 100g was recently proposed as a safe level to support precautionary allergen labelling (PAL). On behalf of the EAACI Taskforce on Food allergen thresholds, a group of experts have responded to the proposal, highlighting many of the complexities of using a blanket threshold to inform PAL and urging caution.
For the original article, Zuberbier et al reviewed previous publications to determine whether a fatal anaphylactic reaction to 5mg of allergenic protein or less has ever been reported and found none. In their editorial response, Turner et al warned that determining the amount of protein consumed to trigger the fatal reaction is extremely challenging, and not all fatal reactions are published. For these and other reasons, they suggest literature reports of fatal food allergy reactions are not an appropriate basis for public health policy.
Turner et al also asserted that consumers with food allergy want more than just “not to die”. Rather, they don’t want to experience any allergic reaction. The proposed threshold would mean that for some allergens, consumers may still experience allergic reactions – including anaphylaxis.
Zuberbier et al suggested a voluntary PAL statement such as “this product contains [the named allergens in the list of ingredients], it may contain traces of other contaminations [to be named, e.g. nut] at concentrations less than 0.5mg per 100g of this product”. Turner et al expressed concerns that this not only goes against international recommendations for expressing detected levels of allergens, but the statement is lengthy, complex and does not meet the identified needs of consumers who seek clear, concise, and easy to understand allergen advice on food labels.
Other concerns raised by Turner et al in relation to use of a blanket threshold include lack of consideration of the unintended presence of allergens as particulates or uneven distribution of allergens in foods; a current lack of reliable analytical methods to accurately quantify all priority allergens at a 5ppm level; and for some allergens, a 5ppm threshold is an over-conservative action level, meaning an unnecessarily high number of products would have a PAL.
They conclude that, while well-intentioned, the approach proposed by Zuberbier et al may be counter-productive to supporting the food industry and regulators to provide safe foods for allergic consumers.
Reference: Turner et al. 2021. Allergy DOI 10.1111/all.15202