Ottawa – Bakers and other flour users could see new precautionary allergen statements on baked goods.
The Canadian National Millers Association (CNMA) says that this is due to the adventitious presence of priority allergens, such as soy and mustard, in wheat and other processed grains.
Allergens can be unavoidably present
The Baking Association of Canada (BAC) says that these allergens, allowed in wheat via Canada’s grain grading regulations, are unavoidably present in unprocessed grains as a consequence of co-mingling in grain harvest, on-farm storage and movement through the grain handling and transportation system.
The practice of the Canadian Food Inspection Agency (CFIA) has been that precautionary statements must be carried through to products made with these ingredients, which will require bakers to apply similar precautionary statements on their own products.
BAC says the CNMA has attempted to work with Health Canada over the past year to clarify Health Canada’s allergen labelling policy as it relates to the adventitious presence of soy and mustard in wheat and wheat flour.
Compounding the urgency for an expedited resolution to this situation, says BAC, is that the CFIA has been engaged also during the past year in product sampling to determine the undeclared presence of soy in a wide range of wheat based foods.
The CFIA product sampling did indeed discover detectable levels of soy.
In July 2012, both BAC and CNMA supported a commitment by Health Canada to conduct a targeted consultation on the adventitious presence of allergens in Canadian cereal grains.
To date, that consultation has not been completed.
Oats and barley
BAC says that further complicating the use of precautionary statements is an unprecedented recent experience by one of its member companies that was served with an allergen recall notice for the unlabelled presence of oats and barley.
While not on Health Canada’s priority allergen list, oats and barley were deemed to be allergens and a recall initiated.
According to the CNMA, says BAC, the low-level presence of oats and barley along with soybeans, mustard seed, rye and triticale should be expected to be found in wheat flour and other milled wheat products as mills cannot remove 100 per cent of their presence.
BAC says it’s most concerned that the recent oats and barley allergen recall adds a new dimension to the whole matter of allergen labelling and the use of precautionary statements.
Removing the uncertainty
Firstly, BAC believes it is precedent setting to order an allergen recall for a non-priority allergen, which could mean that any ingredient currently not on the priority allergen list may subsequently be deemed an allergen and subject to recall if unlabelled.
Secondly, as Canada’s grain grading regulations allow for the co-mingling of soy, mustard, oats, barley and many other cereal grains, BAC members face an untenable business risk as wheat flour-based products could be subject to allergen based recalls at any time.
BAC says it is currently pressing both Health Canada and the CFIA for clear guidance to remove the uncertainty regarding the adventitious presence of both the priority allergens along with oats and barley.
BAC and other members of the grain supply chain are engaged in a consultation in an attempt to resolve issues surrounding the use of precautionary labelling of wheat flour and other cereal grains.
BAC says it will be seeking solutions that do not result in further extensions of precautionary allergen labelling, such as the establishment of tolerance thresholds along with consideration of supply chain mitigation methods.