Thresholds and ?Free From? ? An explanation

The food industry has made huge improvements in recent years in its provision of products for the food allergic community as well as those with specific dietary needs.

However, we have recently found that there can be confusion about the difference between foods marketed as being “Free From” a particular ingredient; and foods that carry a warning that they may be at risk of contamination from certain allergenic ingredients, i.e. “May Contain” warnings.

To try to explain the differences and also some of the risks involved with both definitions we have created the guide below.

Free From Foods

In recent years there has been a huge increase in this food sector. Food manufactures have recognised the need for consumers to have a choice of food which does not include their allergen/s or ingredients that can cause intolerances.

The Anaphylaxis Campaign views this as an excellent development, and we are working with a lot of these companies.

However caution still is still advised, and we would urge those with food allergies to take into account these points:

• Other than “gluten free”, there is no legal definition of ‘Free From’ – so a manufacturer  could theoretically make this claim if a product does not have a particular allergen added as a deliberate ingredient  e.g. milk in the recipe, however traces of milk may be present where the food was prepared or packaged.
• There is no legal requirement for these foods to be scientifically tested and checked to ensure that no traces of the allergen are present.
• Food producers creating products for the Free From market vary considerably. Many will have effective procedures in place to ensure the safety of their products, including stringent testing. Others may not employ the same levels of high quality testing and production.   
• Food intolerance and food allergy are very different.  The main difference being that food allergies can be fatal.  Many consumers have gluten/wheat intolerance or coeliac disease, and only foods that contain 20 ppm or less can be labelled as 'gluten-free'.  Some people with a wheat allergy however may react at this level. Pre-packed foods containing gluten at less than 20ppm would still need to have the gluten-containing cereal listed in the ingredients due to allergen labelling regulations, even if the product carried a “gluten-free” statement.

Thresholds

For some years, scientists around the world have been working towards an understanding of threshold doses for food allergens – the lowest amount that can trigger an allergic reaction. Once a threshold dose has been established for each allergenic food, then industry can make efforts to reduce cross-contamination to below those levels. The result might be fewer “may contain” warnings.

The case against establishing thresholds

Not everyone agrees with the idea of thresholds. The main argument against is based on the perception that minute traces can kill. Although this perception may be largely founded on scare stories and extreme cases, it must be acknowledged that small amounts of an allergen can trigger symptoms in people who are highly allergic. Whether these symptoms are life-threatening is beside the point. Any symptoms requiring treatment are unpleasant and alarming.

Furthermore, an allergic person’s own threshold can vary from day to day. How much they react to at any given time may depend on factors such as their general state of health, how well their asthma is controlled, whether they have been exercising strenuously or drinking alcohol, and other factors. Even if industry works to agreed thresholds, would these limits be misleading if a person can react to lower amounts at certain times?

People are right to question whether any industry actions based on agreed thresholds will protect 100 per cent of the allergic population all of the time. The answer is that there is likely to be a very small minority who are so susceptible that they could react to an amount below the threshold.

The case for thresholds

There are various strands to this argument:

• Setting quantitative thresholds should result in more consistency in allergen management throughout the food industry and consequently greater safety for people with allergies. It would also allow much better communication to healthcare providers and consumers of the meaning of “may contain” labels.
• The most severe allergic reactions are normally caused, not by traces, but by significant quantities of allergen, intentionally added to the food. In such cases, there is usually a major error made somewhere along the way, either by the person supplying the food or the person eating it.
• The study described above offered reassuring evidence that reactions to small amounts of an allergenic food will be mild in the vast majority of cases.
• Total elimination of risk is impossible in any area of life, but risk minimisation is achievable.  This does not mean that even one life can put at risk. However, most people with food allergies may accept that the occasional very minor reaction may occur.
• Food industry action based on agreed thresholds will lead to a reduction in “may contain” labels and make those that remain more meaningful.

The Anaphylaxis Campaign is supportive of the concept of thresholds and looks forward to this work being developed further.