Since Jan. 1, 2006, all labels for packaged foods regulated under the Federal Food, Drug and Cosmetic Act (FFD&C Act) must comply with FALCPA’s (Food Allergen Labeling and Consumer Protection Act) food allergen labeling requirements. With the FDA labeling mandate in effect, bakers are dealing with greater consumer awareness of allergens.
More than 160 food ingredients are recognized as allergens, but the FDA focus is on the big 8: peanuts, soybeans, fish, crustaceans, milk, tree nuts, eggs and wheat. These can cause serious allergic reactions including death, and they account for more than 90 percent of all food allergies. Published FDA statistics estimate that about 30,000 American consumers require emergency room treatment and 150 die each year because of allergic reactions to food.
The seriousness of food allergies requires labeling with common, understandable language and full disclosure on all ingredients.
“With more bakers using ingredients such as protein isolates, it is not enough to state this on a label without noting the source of the isolate, which may be milk, soy or nuts. This can be very confusing and dangerous for the public,” says Pramod Kelkar, partner, Allergy and Asthma Care, Maple Grove, Minn., and spokesperson for the Academy of Allergy, Asthma and Immunology. “It is very important that this be broken down into simple language that every consumer can understand and easily identify the origin of the isolate.”
It is in the best interest of bakers to put all information that cannot be contained on a label on their Web sites, Kelkar advises. “If there is a long list of potential sources or the slightest potential for cross contamination, bakers should direct the consumer from the label to their Web sites for full disclosure,” he says.
Dealing with cross contamination
The issue of cross contamination is not currently mandated, but is being considered by the FDA. However, with shared equipment, cross-contact risks can be significant for bakeries. Forward-thinking bakers are erring on the side of caution. Joel Payne, senior scientist, corporate food technology, The Kroger Co., Cincinnati, says Kroger’s bakery approaches the issue in several ways. The first and primary direction is to eliminate any unnecessary allergens. An example is products that included gelatin made from fish bones and cartilage. Rather than list all types of fish that might have been used in producing the gelatin, Kroger eliminated it from its formulas.
“Obviously, if we have an allergen in the product, we list it. If we have to process [products with] different allergens on the same production line, then we stop and do an allergen wash down of all the equipment that’s involved between products. That is a substantial economic cost, so we try to avoid allergen mixing as much as we can,” Payne says.
Strict cross contamination policies are needed, agrees Julius Walls, president and C.E.O. of Greyston Bakery Inc., Yonkers, N.Y. “I’m sure very few bakeries produce products with no allergens. We make products with eggs, milk, soy and nuts, but we have very strict handling procedures in place including heightened observation and very intense wash down for all allergen lines. We also have a separate line that runs products with nut allergens,” he says.
Most of the bread lines at Kroger use wheat and soy, which are listed clearly on the label. However, the bakery also produces some breads containing milk or a butter topping. To avoid cross contamination, the nondairy products are run first, then products containing dairy ingredients (both formulas have wheat and soy). “We try to incorporate our allergen wash downs with our regular daily equipment wash downs,” Payne says. “That way we start with a clean, fresh line everyday.”
While most commercial baking surfaces are cleanable, it is difficult to completely remove all traces of allergens, especially from mesh or cloth belts, and shared equipment is a huge source of cross contamination. “Saltines don’t normally have a milk allergen, but there is no way to completely ensure that the milk [from other products] is off of the belt, so we now list milk as an allergen on our saltine crackers,” Payne says.
If bakers are in doubt about what to list on labels, list all possible allergens from the bakery, says Anne Munoz-Furlong, C.E.O. of the Food Allergy & Anaphylaxis Network (FAAN), Fairfax, Va. All allergens need to be disclosed. If products are processed on shared equipment with a risk of cross-contact, add the allergy information to the product label.
According to medical sources, even a trace amount of an allergen can cause a reaction. The allergen does not have to be ingested to cause a reaction; skin contact or inhalation can trigger it. Nobody is more aware of this situation than Payne, who is highly allergic to all grain-based products. “We have one manager at another plant with a peanut allergy–and he has to run peanut butter cookies,” Payne says. “We know the risks, and we are extremely careful to do what is best for this type of consumer because we are ‘those’ consumers.”
Most wholesale bakers have some way to handle the cross contamination in the plant, but those supplying par-baked products lose control once the products are in the retailers’ hands.
“We’ve found that we can control the allergen situation in our manufacturing plants, but we don’t have the same control over the possibility for allergen cross contamination in our in-store bakeries,” Payne says. “Therefore, all of our cookies and so forth now carry an additional label indicating that they are produced by in-store equipment that also processes a list of all the possible allergens.”
The market for allergen-free products is growing as manufacturers try to meet consumer demand. One potential source for allergens that is often overlooked is release agents. Soy lecithin is a common ingredient in release agents, and it contains trace amounts of soy proteins, which must be declared as allergens. Avatar Corp., University Park, Ill., offers a line of non-allergenic release agents. “Our ProKote™ products have been shown to outperform soy lecithin-based products,” says Sarah Bozzo, inside sales and marketing specialist. “They also demonstrate excellent heat stability and therefore color integrity of baked goods.”
Weizhu Yu, product development center manager, Caravan Ingredients, Lenexa, Kan., says customer requests to remove allergens, particularly soybeans (soy flour and soy lecithin), eggs and milk, have led to the redevelopment of existing Caravan products, expanding offerings to include new product lines and audiences. “When developing new products, the customers will often have specific allergens they want to avoid, so a quick conversation will clarify the necessary restrictions before any development work begins,” Yu says.
The company also receives about one to two requests a month to remove sesame seeds and sesame flour from products because ingredients with protein are seen by bakers to be a potential issue. “The requests have stretched across our product range from bread bases to spice blends and have come from a cross section of customers,” Yu says.
Enjoy Life Natural Brands LLC, Schiller Park, Ill., has been baking allergen-free products for five years. All products are both gluten-free and free of all the big 8 allergens. The bakery offers cookies, snack bars and bagels made with alternative flours, and has grown from an entrepreneurial concept to having products in stores across the country and Canada.
“Replacing wheat, eggs and soy is a challenge. I don’t want to say it’s not difficult because it is,” says Scott Mandell, president and C.E.O. “But that’s what makes us unique. We have food scientists on staff who work with this. Our business has been doubling in size, year after year. We just moved into a larger facility and are already expanding into another.”
Michael Girkout, president, Alvarado Street Bakery, Rohnert Park, Calif., notes that although wheat and soy are going to always be essential ingredients, the bakery is committed to not exposing its customers to other major allergens. “In addition to being certified organic, we are also a certified kosher (pareve) facility and never use any dairy products or eggs in anything we bake,” Girkout says. “We are especially sensitive to the peanut and tree nut issue, and have a very strict policy of never allowing any tree nuts or peanuts into our facility. All recipe development now, and in the future, will be done without the use of these ingredients.”
Alvarado products’ nutty “crunch” and texture comes from other ingredients, such as sunflower seeds, pumpkin seeds and toasted soy, which produce the same texture and often, better flavor than nuts.
The gluten issue
The FDA is proposing to define the term gluten-free for voluntary use in the labeling of foods. FALCPA has required the FDA to issue a final rule on the gluten-free labeling issue no later than August 2008.
Establishing a definition of gluten-free, and uniform conditions for its use in the labeling of foods, is needed to ensure that individuals with celiac disease are not misled and are provided with truthful and accurate information.
“Eating any gluten, no matter how small an amount, can damage the intestine [of celiac sufferers], leading to serious inflammation,” says Becky Kowalkowski, patient services director, National Ataxia Foundation, Minneapolis.
Heartland’s Finest, Hillman, Mich., entered the gluten-free market in December 2004 with a bean-based flour and has since added many products. Jim LeCureux, general manager says the FALCPA labeling issue has generated new business. “We provide the base flours for bakers, and we provide a list of recipes for them to use as starting points for our gluten-free flours,” he says.
Flavor is important for bakery products and can be a challenge in allergen- and gluten-free products. “Fortunately, Edlong has formulated many of our flavors to be gluten-free and can supply customers with certification of flavors to meet their needs,” says Paul Patel, senior regulatory specialist for Edlong Dairy Flavors, Elk Grove Village, Ill. Edlong’s current portfolio includes an increasing number of dairy flavors that are free of all allergens. Although flavors are used in very small quantities, any allergens contributed by the flavors have to be declared on the product label. This has opened up new avenues of products for bakers and mix suppliers who want to tap into the allergen-free, gluten-free market without sacrificing flavor.
The new classification of coconut as a tree-nut allergen resulted in reformulation requests from many customers, which was not an easy replacement, Patel says. Coconut components used in flavor development provide a unique creamy characteristic, mouthfeel and flavor profile. “Our flavorists had to work to develop acceptable alternative flavors that would match the characteristics of coconut components,” he adds.
An estimated 12 million Americans, or one in 25 people, suffer from food allergies, which influences their family’s food buying decisions. “The industry needs to recognize that individuals with food allergies want to be able to eat comfort foods, such as baked goods, and when they find a company they trust, they become very loyal customers,” FAAN’s Munoz-Furlong says. “It makes good business sense to pay attention to food allergies.”