Memorandum submitted by the Food Standards
Agency
INTRODUCTION
The Role of the Food Standards Agency
Responses to questions posed by the Committee
that are relevant to the work of the Food Standards Agency
Defining the problem
What is allergy? What is the difference between
allergy and intolerance?
What is and what is not known about the origins
and progression of allergic disease? Why is the incidence of allergy
and allergic diseases rising?
Why does the UK in particular have such a high
prevalence of allergy?
Treatment and management
Is the level of UK research into allergy and
allergic disease adequate?
What are the most promising areas of research
into preventing or treating allergy?
Government policies
How effectively are food policy and food labelling
regulations responding to the rise in food allergies?
Patient and consumer issues
What impact do allergies have on the quality
of life of those experiencing allergic disease and their families?
What can be done to better educate the public
and to improve the quality of information that is available to
patients and undiagnosed sufferers?
Are current regulatory arrangements, for example,
those governing private clinics offering diagnostic and therapeutic
services and the sale of over the counter allergy tests, satisfactory?
INTRODUCTION
The role of the Food Standards Agency
The statutory objective of the Food Standards
Agency (the Agency) is to protect the health of the public and
the other interests of consumers in relation to food and drink[1].
The Agency was set up in April 2000 as a separate Government department,
at arm's length from the political process (although accountable
to the Westminster Parliament and to devolved equivalents through
Health Ministers) and with a clear objective. The independence
of the Agency is given effect both by its formal status as a non-Ministerial
UK Government Department, led by a Board appointed by UK Ministers
to act in the public interest and by its powers to publish the
information and advice that it issues, including advice to Ministers.
Our role in relation to food allergy and intolerance
is to develop policies that allow consumers to make informed choices
about their diet. We do this by negotiating and implementing legislation
to improve statutory control on labelling of food allergens, and
also by providing best practice guidance for industry and enforcement
bodies to encourage greater awareness and control of food allergens
through the food supply chain. We also provide advice about food
allergy and intolerance for consumers so that they understand
and can use the information provided to them by food businesses.
We do this via our website and through published materials to
help consumers make informed food choices that will ensure their
safety, whilst not unduly restricting the choices available to
them. We also commission scientific and consumer research on food
allergy and intolerance to ensure that policies are based on robust
evidence.
Food labelling is an area of EU competence and
therefore national legislation in this area implements the relevant
EU legislation. We negotiate on behalf of the UK to ensure that
EU legislation in this area addresses the needs of UK consumers
and industry. However we also produce best practice guidance to
advise industry and enforcement bodies in areas not currently
covered by EU legislation and also help to ensure appropriate
training is provided.
We have responsibility for food policy and therefore
this submission concentrates on food allergy and intolerance.
However, the symptoms seen in many people exhibiting allergic
reactions to foods include those associated with other non-food
types of allergy (such as respiratory and dermal reactions), as
well as gastrointestinal symptoms and possibly anaphylactic shock.
Proper diagnosis and appropriate dietary avoidance strategies
may help to reduce the incidence of respiratory and dermal allergic
reactions. There is evidence (Pumphrey, unpublished data) to show
that a significant proportion of fatal asthma attacks are triggered
by allergic responses to foods that exacerbate existing, poorly
controlled asthma. Furthermore, sulphites used in many foods as
a preservative are also known to trigger attacks in a proportion
of asthmatics. In addition, egg and milk allergies are associated
with eczema in young children.
RESPONSES TO
QUESTIONS POSED
BY THE
COMMITTEE
The Agency welcomes the opportunity to provide
evidence to this inquiry. We have structured the main part of
our evidence around those questions posed by the Committee in
its call for evidence that are relevant to our remit.
1. DEFINING THE
PROBLEM
What is allergy? What is the difference between
allergy and intolerance?
1.1 Although food allergy and food intolerance
are both types of food sensitivity, they are different conditions.
The main differences between them are that food allergy involves
the immune system, and specifically the production of IgE antibodies
against the food protein in question, whereas food intolerance
generally does not involve the immune system. Other differences
include the length of time it takes for symptoms to appear and
the type of symptoms involved. When someone has a food allergy,
their immune system reacts to a particular food as if it is not
safe. This causes immediate symptoms, which generally include
itchiness, rashes and swelling, but can also include more severe
respiratory and gastrointestinal symptoms. Sometimes this reaction
is so severe that people can experience life-threatening anaphylactic
reactions, which affects the whole body, often within minutes
of eating the food, although this can take longer.
1.2 The foods that most commonly cause allergic
reactions in the UK are peanuts, tree nuts (such as almond, hazel
nut, walnuts, and Brazil nuts), milk, eggs, fish and shellfish
but many other foods are also capable of inducing allergic reactions
in some individuals.
1.3 Food intolerance generally does not
involve the immune system, although gluten intolerance (coeliac
disease) is an auto-immune disease. Some food intolerance reactions
are caused by an inability to digest a particular food, for example
because of a lack of a specific enzyme (such as lactase in people
with lactose intolerance), but often the mechanism of the reaction
is unknown. Usually symptoms are not immediate although there
are some preservatives and flavour enhancers that can cause flushing
or wheezing in asthmatics soon after eating. The symptoms can
be unpleasant and severe in some cases and they can affect long-term
health, but they are generally not life-threatening.
1.4 People with a food allergy need to avoid
all forms and traces of that food, however small the amount. However,
people with food intolerances can often tolerate small amounts
of the food without noticeable symptoms, although the amounts
that can be eaten without symptoms will vary.
1.5 There are many foods that people can
be intolerant to, but the most common food intolerances are to
milk (cows' milk protein intolerance) and lactose (milk sugar),
gluten (a protein found in cereals such as wheat, barley and rye),
wheat, food preservatives, and naturally occurring compounds in
foods, such as caffeine and some amines.
What is and what is not known about the origins
and progression of allergic disease?
1.6 We know the basic immunological mechanisms
of food allergy and how reactions occur. Allergic diseases normally
develop in two phases. First exposure to the inducing allergen
results in a primary immune response (sensitisation) which primes
the immune system for subsequent exposure to that allergen. When
the sensitised person is subsequently exposed to the same (or
a cross-reactive) allergen, there is an accelerated and more aggressive
immune response that results in an inflammatory reaction and the
clinical manifestation of allergy. The reaction is usually caused
by specific IgE antibodies that are reactive with the food protein.
These IgE antibodies attach to certain cells in the immune system
and bind to the allergen. When they bind to the allergen, there
is a resulting cascade of reactions that cause the clinical symptoms
of an allergic reaction.
1.7 There are a number of other factors
that help to determine whether an individual is likely to develop
an allergic condition, including genetics and the ways in which
they are exposed to an allergen (route, age and amount). Further
details on these factors can be found in Annex I.
1.8 It is difficult to estimate the proportion
of people with food allergy who will experience severe, possibly
fatal, reactions. However, the most common identifiable causes
of anaphylaxis are foods, medications, insect stings and allergen
immunotherapy injections, with anaphylaxis to peanut and tree
nuts being of particular concern because of its life-threatening
potential. It is reported that one in two children with peanut
allergy experience life-threatening symptoms with subsequent reactions.
In 2004-05 there were 829 hospital admissions in England caused
by anaphylactic reactions to food[2]
and a recent analysis of trends in admissions to hospital for
food allergy has shown an increase of 500 per cent since 1990,
with some evidence for an increase in the prevalence of peanut
allergy in children. People vary considerably in their sensitivity
to particular food allergens, and there is also considerable variability
within an individual on different occasions, depending on factors
such as the amount of the allergen consumed, the food matrix in
which it is present, the underlying health of the individual and
other as yet unknown factors. There is evidence to show that allergic
reactions to foods can be significantly more severe in people
with asthma.
1.9 However areas of uncertainty remain
where further research is needed, including the role and importance
of other (non-IgE) immunological factors on the regulation of
the allergic response and the determination of whether an individual
becomes allergic or tolerant to a particular allergen. Other emerging
areas of interest include the role of T lymphocytes, including
T regulatory cells, in determining immune status, the roles of
other classes of antibody, such as IgG, in the food allergic response
and an understanding of why proteins differ in their ability to
cause food allergy.
Why is the incidence of allergy and allergic diseases
rising? Why does the UK in particular have such a high prevalence
of allergy?
1.10 Although there are a variety of existing
hypotheses to explain the rise in the prevalence of atopic (a
tendency to produce an IgE antibody response to a range of allergens)
allergy and allergic diseases (see Annex I), there is no single
agreed cause at the current time. Whilst the UK may have a higher
incidence of some food allergies than some other countries, these
countries may have a higher incidence of different food allergies.
For example, there is a higher incidence of fish allergy in Scandinavia
and a higher incidence of rice allergy in the Far East than in
the UK. Differences in dietary habits and practices are thought
to have a major impact on the incidence of particular food allergies
in different countries but this is unlikely to be the only causative
factor and research is ongoing to look at other possible reasons
for observed differences. Further evidence on the prevalence of
food allergies in the UK is given in Annex I.
2. TREATMENT
AND MANAGEMENT
Is the level of UK research into allergy and allergic
disease adequate?
2.1 We cannot comment on the adequacy of
research into allergy in general. However we have a food allergy
and intolerance research programme, which was established in 1994
by the then Ministry of Agriculture, Fisheries and Food and taken
over by the Agency, when it was established in April 2000. The
main aims of this programme (designated T07) have been to characterise
factors that influence the pathogenesis of these conditions, focussing
initially on peanut and tree nut allergy and on the later stages
of allergic disease, when allergy has already developed. More
recently the programme has been investigating what the prevalence
of food allergy in the UK is and whether it is increasing, the
factors that govern inter-individual differences in susceptibility
to food allergy and whether it is possible to identify those at
risk of developing food allergy. The programme has also included
work on thresholds for sensitivity to gluten in order to better
control the composition of foods for coeliac patients that are
described as "gluten-free", the characteristics of kiwi
fruit allergy and the possible effects of some food additives
on behaviour in children.
2.2 In 2000, the Committee on Toxicity of
Chemicals in Food, Consumer Products and the Environment published
a report on adverse reactions to foods and food ingredients, which
included a number of recommendations for research. Whilst some
of these recommendations were directed at clinicians, academia
and the Department of Health, others have been addressed within
the Agency's T07 programme. The outcomes from the T07 programme
have been summarised in Annex II, but a number of other studies
are still in progress. These address a range of important issues,
including further investigations on the role of pre- and post
natal exposure to allergens in the development of allergy or tolerance
to food proteins, and the role of T cell responses in the development
of allergic sensitivity or tolerance, the possible effects of
additives on the behaviour of children and thresholds for tolerance
to gluten. A list of the projects within the programme can be
found in Annex II, and further details about the individual projects
can be found on our website[3].
2.3 This T07 programme was reviewed by independent
experts in 2003 as part of a 5-yearly review cycle. The reviewers
were complimentary regarding the outputs from the programme which
increased understanding of the prevalence and mechanisms of food
allergy and also resulted in specific information that led to
improvements in the advice available to those affected. The review
report,[4]
which was published on the Agency's website, noted the need for
the Agency to work with other funding bodies, both to improve
the robustness of the research that is commissioned and to provide
better value for money when the funding for such research is limited.
What are the most promising areas of research
into preventing or treating allergy?
2.4 It should be noted that, at present,
the only treatment for food allergy is avoidance of the food(s)
in question. Although desensitisation treatments exist for some
allergic diseases, such as hay fever, such approaches are not
yet available for food allergies. Medication only deals with symptoms
of a reaction once it is happening and medication, such as adrenaline
injections, may not be effective if given too late after the reaction
starts. There have been recent reports of work to produce recombinant
versions of some of the allergenic proteins from foods that have
been modified to reduce their allergenicity, which could then
be used to desensitise the body's immune system (immunotherapy),
although actual treatments are still some years away.
2.5 The Agency considers that key areas
for research are to determine:
— appropriate weaning practices for
children, both those with and those without atopic backgrounds,
with respect to the timing of introduction of the main allergenic
foods, and the frequency and amounts to be given, so as to reduce
the risk of allergy developing and promote the development of
tolerance; and
— thresholds for allergens that can
be used by the food industry to inform labelling decisions.
The Agency issued a call for research proposals
to address these questions in March 2006 and is currently considering
possible projects for funding.
3. GOVERNMENT
POLICIES
How effectively are food policy and food labelling
regulations responding to the rise in food allergies?
3.1 One of the key aims of the Agency is
to enable consumers to make informed choices about the foods they
eat. In response to the apparent increase in the prevalence of
food allergy and intolerance in the UK, we set out in our Strategic
Plan for 2005-10[5],
that we would work to ensure that people with these conditions
have the right information to ensure their safety and to prevent
their choices from being unnecessarily restricted.
3.2 The Board of the Agency first discussed
food allergy and intolerance at its open Board meeting in February
2003,[6]
in relation to a need for clear labelling and information, and
agreed at that time to develop an Allergy Action Plan. Such a
plan was agreed at a further open Board meeting in September of
that year[7]
and updates on progress have been discussed by the Board subsequently
in September 2004[8]
and April 2006.[9]
3.3 The Agency's Allergy Action Plan incorporates
a number of elements, including improving food labelling (both
statutory and voluntary), raising awareness of food allergy issues,
particularly amongst caterers, and improving training, both for
those working in all sectors of the food industry and for Local
Authority enforcement officers. The Plan also encompasses improving
the information available to consumers so that they can understand
and use the labelling on the foods they buy. The Board will continue
to review the progress of these initiatives and the Action Plan
will evolve in response to changing needs. Further details regarding
food allergen labelling, both statutory and voluntary, are given
in Annex III.
3.4 Enforcement of allergen labelling legislation
rests with Local Authorities but investigating incidents to ensure
food safety is protected and food is correctly described is a
key part of the Agency's work. If an allergen present in a food
is not correctly labelled, the affected food may be withdrawn
or recalled and information is provided to enforcement bodies,
and is also published on the Agency's website. In addition, the
Agency works to ensure that consumers with food allergies or intolerances
are also informed of such incidents via their consumer support
organisations. Food premises, including catering businesses, are
inspected and assessed by Local Authority enforcement officers,
and recent guidance to catering businesses on the implementation
of safe catering practices included a section on good allergen
control.
4. PATIENT AND
CONSUMER ISSUES
What impact do allergies have on the quality of
life of those experiencing allergic disease and their families?
4.1 People with food allergies and intolerances
face a range of dietary and social restrictions, depending on
the numbers and types of foods to which they react. There is evidence
to show that 9-10 year old children with peanut allergy have a
significantly poorer quality of life than children of a similar
age with insulin-dependent diabetes mellitus. Peanut allergic
children reported more fear of an adverse reaction and more anxiety
about eating, especially away from home. They also felt more threatened
by potential hazards in their environment and more restricted
concerning their physical activities.
4.2 Currently the choice of foods for allergic
consumers can be limited and the financial costs for allergic
consumers are higher than those who are not on a special diet.
An FSA study in 2002 on "May Contain Labelling—The
Consumer Perspective" found that nut allergic consumers took
an average of 39 per cent longer to shop and paid 11 per cent
more for food.
4.3 Consumer research conducted by the Agency
in 2005 into the information needs of teenagers with food allergies
and intolerances showed effects on social and inter-personal life,
difficulties in fitting in with peer groups and dietary restrictions.
Given that many social interactions in this age group are centred
on eating and drinking, such conditions significantly impair their
quality of life. There is evidence that a significant proportion
of adolescents and young adults admit to risk taking behaviours
(such as eating foods that carry `May Contain' labelling, a reluctance
to ask questions about the allergen content of foods, especially
in restaurants, and not carrying their medication), partly in
response to a desire to avoid social isolation.
4.4 In addition to providing information
for consumers, the Agency also raises awareness of food allergy
issues with food businesses and Local Authority enforcement bodies,
by providing best practice guidance and helping to ensure that
appropriate training is available (see Annex III).
What can be done to better educate the public
and to improve the quality of information that is available to
patients and undiagnosed sufferers?
4.5 Ewan and Clark demonstrated that the
adoption of good management plans by food allergic patients (including
detailed advice on avoidance strategies, treatment plans and prescription
of medication for self administration) reduced the rate of adverse
reactions from about 50 per cent to 15 per cent.
4.6 The Agency has produced a fact sheet
for those with food allergies and intolerances to help them successfully
avoid the foods to which they know they react,[10]
including information on understanding food labels and advice
for when eating away from home. This was made available on the
Agency's website in December 2004 and was subsequently publicised
to health professionals via the GP and Chief Nursing Officer Bulletins
issued by the Department of Health. Following feedback from dieticians,
the Agency has recently updated this fact sheet, separating the
information into two separate documents, one covering food allergies
and the other food intolerances. This update was conducted in
partnership with the British Dietetic Association and is being
publicised to their members via their website.
4.7 The Agency has a consumer-facing website[11]
that contains a section on food allergy and intolerance issues,
including background information on these conditions, and the
foods likely to provoke such reactions, as well as advice on buying
foods both in retail and catering settings. In addition, there
is an `Ask on Expert' function that allows consumers to pose questions
which are replied to individually and some of the points raised
are incorporated in a Q&A section on the website[12].
Furthermore, the Agency provides information on its website explaining
food labelling, including allergen labelling and information is
also provided in the form of leaflets.
Are current regulatory arrangements, for example,
those governing private clinics offering diagnostic and therapeutic
services and the sale of over the counter allergy tests, satisfactory?
4.8 We cannot comment on the regulation
of diagnostic and therapeutic services. However we receive many
requests from consumers who have used over-the-counter allergy
tests (many of which have not been formally validated for diagnosing
food allergy), seeking advice to help them comply with the recommendations
they have been given as a consequence of using these tests, to
remove many basic foods, such as wheat and dairy products from
their diets. We are concerned that many people follow such recommendations
and restrict their diets unnecessarily without receiving proper
clinical and dietetic support, which could lead to nutritional
problems. We provide advice on our website and in response to
correspondence that people should always seek advice from health
professionals and dieticians before making major changes to their
diet. The issue of un-validated tests was also addressed by the
Royal College of Pathologists, who concluded that commercial allergy
tests were not recommended and that some were of dubious scientific
value. They also concluded that testing for allergy without first
knowing a patient's medical history was poor practice and likely
to be unhelpful or misleading.
Annex I
FACTORS THAT
INFLUENCE THE
LIKELIHOOD THAT
AN INDIVIDUAL
WILL DEVELOP
AN ALLERGIC
CONDITION
1. There is a subgroup of the population
with a predisposition towards mounting IgE antibody responses
to allergens (atopic individuals). In addition, children whose
parents and/or siblings have allergic diseases have a higher risk
of themselves developing allergic diseases, although the form
that the allergic disease takes may vary, depending on interactions
with environmental factors and the nature and timing of exposure
to potentially sensitising proteins.
2. One factor that influences the acquisition
of atopy is programming of the developing immune system in the
young infant. There is some evidence that increased protection
of infants from pathogens and environmental non-pathogenic micro-organisms
is associated with an increased prevalence of atopy (the so-called
hygiene hypothesis). However, there is no unifying hypothesis
concerning the exposure to overt viral and bacterial infection,
the significance of environmental exposure to microbial compounds
and the responses of the innate and adaptive immune processes.
A recent review of evidence points to the view that fundamental
changes in lifestyle that have led to decreased exposure to certain
microbial or other species, such as helminths, rather than infection
with pathogenic organisms or changes in domestic hygiene are important
for the development of immunoregulatory mechanisms. Food safety
measures are generally targeted at pathogens and do not aim to
produce a sterile environment.
3. We do not know definitively why the prevalence
of atopic allergic disease has risen in recent years but other
possible causes include changes in diets and the introduction
of "new" foods (eg peanuts in the 1940's and kiwi fruit
in 1970's) may have led to an increase in the prevalence of some
food allergies. Peanuts are now commonly eaten roasted rather
than raw, and roasted peanut is known to be more allergenic than
raw peanut.
4. Some individuals have been reported to
react on their first known exposure to peanut, generating the
hypothesis that maternal transfer of the allergen or immunological
components may be an important factor in the development of food
allergy. It is recognised that intrauterine immunological sensitisation
can occur and that transmission of food allergens to infants via
breast milk in an un-degraded form may be a route of neonatal
sensitisation. Research on the influence of maternal diet during
pregnancy and the development of food allergy in the offspring
is still inconclusive and the Agency is currently funding research
in this area. Peanut allergy is highly associated with a family
history of allergic disease, and it is currently not possible
to discount the possibility of a link between consumption of peanut
by the mother during pregnancy and lactation and the incidence
of peanut allergy in the offspring. Therefore the Government issued
precautionary advice to mothers in 1998 to avoid eating peanuts
and peanut products during pregnancy and breastfeeding if their
child had a family history of allergic disease.
5. Other factors that may be important in
the development of food allergy include the age of first exposure
to the allergenic food and the route of exposure. Weaning practices
have changed significantly over the last 50 years, with evidence
suggesting a trend towards the later introduction of solid foods,
including commonly allergenic foods. There is currently a lack
of evidence on the optimum times to introduce the common allergenic
foods into the weaning diet, either in children from atopic or
non-atopic backgrounds. Given that there is currently no cure
for food allergy, it is important that evidence-based advice on
the introduction of allergenic foods into the weaning diet is
developed so as to minimise, where possible, the number of children
that develop food allergy. The Agency called for research proposals
to address this question in March 2006[13]
and is currently considering possible projects for funding.
6. Recent research has demonstrated that
dermal exposure may be an alternative route of sensitisation for
food allergens (especially peanut), perhaps through use of creams/oils
or through general low level environmental exposure if others
in the household are eating peanut. Such low level dermal exposure,
especially to broken skin, is associated with sensitisation and
clinical allergy whereas high level oral exposure may lead to
tolerance.
7. Furthermore there may also be an increase
in occupational exposure to allergens, such as latex, which is
known to cross react with a number of fruit allergens associated
with oral allergy syndrome. In addition exposure via inhalation
may be important in some situations, for example those preparing
and cooking fish may react to the vapours produced.
PREVALENCE OF
FOOD ALLERGIES
8. It appears that there has been an increase
in the incidence of at least some food allergies in recent years,
which is in line with the general increase in the prevalence of
atopic allergic diseases. An increase in clinical peanut allergy
in early childhood from 0.6 per cent in 1989 to 1.5 per cent in
1994-96 has been reported in the UK, with rates of sensitisation
increasing from 1.1 per cent to 3.3 per cent over the same period.
Peanut allergy is reported to be presenting earlier in childhood
and is more common in siblings of people with peanut allergy.
There is a similar situation in the US where the prevalence of
peanut allergy was found to have doubled in American children
under five years of age over a five year period.
9. Definitive figures for the prevalence
of individual nut allergies in the UK are currently lacking. Peanut
allergy is the most common cause of severe (fatal and near fatal)
allergic reaction to foods. The Agency is funding projects to
determine the current prevalence and incidence of specific food
allergies in the UK and whether food allergy has increased in
the last 20 years, including studies to investigate the effect
on the incidence of peanut allergy of the issuing of the Government
advice on the avoidance of peanut during pregnancy and lactation
by mothers whose child has an atopic family background. One of
these projects is part of a large European wide study (Europrevall[14])
funded by the European Commission's 6th Framework Programme. This
will provide definitive data on the current incidence of a number
of food allergies amongst children and adults across Europe (nuts
will be included). The project is due to end in 2010 and the Agency
is funding the UK birth cohort from this study.
Annex II
FOOD STANDARDS
AGENCY RESEARCH
PROGRAMME
1. This programme has extended and deepened
knowledge and understanding of the prevalence and mechanisms of
food allergy, and has revealed new information about different
food allergies, and their causes and mechanisms, which has led
to improvements in the advice the Agency provides. In particular
the programme has:
— Provided evidence that dermal exposure
to allergens such as peanut, especially on broken skin, is a risk
factor for the development of peanut allergy. Such exposure includes
the topical application of creams containing peanut oil and possibly
also low level environmental exposure to peanut allergens in the
home if peanut products are consumed by other family members.
— Investigated the role of maternal
diets in the initiation of allergic disease. Early studies indicated
that the majority of peanut allergic individuals react to their
first known exposure to peanut and that it is not possible to
rule out a link between consumption of peanut by the mother during
pregnancy and lactation and the incidence of peanut allergy in
the offspring. The Government therefore issued precautionary advice
in 1998 for pregnant and breast feeding mothers whose children
had a family history of allergic diseases to avoid consuming peanuts.
However, subsequent studies have failed to demonstrate a conclusive
link between the development of peanut allergy in children and
the levels of circulating peanut antibody in the mothers' blood
or breast milk. Other studies have failed so far to demonstrate
a link between maternal exposure to allergen and the development
of food allergy in their offspring. However the Agency is funding
a further study on egg allergy to follow up preliminary data suggesting
that the level of exposure to the allergen might be critical in
determining any effect. These studies have also demonstrated the
difficulties faced by mothers who try to completely avoid common
allergens such as egg or milk. Studies have also investigated
the impact of the Government advice on peanut avoidance during
pregnancy and lactation and the subsequent prevalence of peanut
allergy in children and these are expected to be published shortly.
— Investigated sensitivity in the same
subjects to peanuts and tree nuts, showing that multiple sensitivity
occurs via sequential sensitisation rather than being due to immunological
cross-reactivity. In general, children have been shown to develop
sensitisation to peanuts first and then go on to develop sensitivity
to one or more tree nuts. This has important clinical and policy
implications and the advice for children sensitised to one type
of nut is now to avoid ingestion of all types of nut. Children
with nut allergy should be periodically monitored for the development
of multiple nut allergies.
— Investigated the roles of T lymphocytes
and IgG antibodies in the development of tolerance to food allergens.
Many children with egg or milk allergy in early life lose their
allergy by age 5 years but allergy to peanut is often life-long.
Several current Agency-funded studies are investigating the mechanisms
involved in the development of tolerance.
— Characterised kiwi fruit allergy
as a new food allergy in the UK. We commissioned work to investigate
this emerging food allergen which confirmed that kiwi fruit should
be considered a significant food allergen capable of causing severe,
life-threatening reactions. Furthermore, in the UK, children are
more likely to experience severe symptoms to kiwi fruit than adults,
possibly because of the age at which they were first exposed to
this allergen. The information has been published in the scientific
press so that clinicians will be better aware of kiwi fruit allergy
(as a relatively new allergy), its characteristics and how to
recognise and diagnose the allergy, which will in turn improve
consumer safety. Information for consumers is also published on
our website.
AREAS FOR
FUTURE RESEARCH
2. Nutritional status in early life has
been associated with general respiratory health in childhood.
It is possible that nutritional factors may modify immune function
and the susceptibility to develop atopic disease, such as asthma.
The Agency is currently in contract negotiations to commission
research on the influence of nutrition on respiratory health and
asthma in childhood. The aim of the study will be to determine
how maternal, infant and childhood diet influences respiratory
health in the first seven years of life. It is expected that the
results of the study will be available from mid 2010.
3. There is some evidence that early introduction
of significant amounts of a food allergen as part of a weaning
diet may help to promote the development of tolerance to food
allergens but definitive evidence to support this, and an understanding
of the optimal ages is lacking. We issued a call for research
to address this issue in March 2006 and are currently considering
possible projects for funding. Opportunities for joint funding
are being investigated.
4. There is at present, a lack of data on
individual clinical thresholds for the main food allergens. There
is also a lack of agreement on threshold levels of allergens present
in foods that should be used for deciding whether or not allergen
labelling is appropriate. This information is urgently needed
to inform both advisory labelling to warn consumers of possible
allergen cross-contamination ("May Contain" labels)
and the criteria needed to be able to designate a food as "free
from" a particular allergen. In addition, information on
levels of allergens for use as a basis for decisions on labelling
will help to ensure that foods are not unnecessarily labelled
when only a very low level of the allergen is present, which would
restrict consumer choice. There needs to be international agreement
of both the threshold levels of allergens in foods above which
they need to be labelled, in order to protect allergic consumers,
and on how these levels should be derived, given the significant
inter and intra-individual variations that exist. We have issued
a call for research proposals to address this issue and are currently
considering how to take this forward.
5. There is also a need for validated detection
methods for the main food allergens and for standard reference
materials to calibrate such methods, and some work on this is
being undertaken by the EU. The European Committee for Standardisation
(CEN) is currently working on the development of standards to
harmonise the development and validation of methods for the detection
and quantification of food allergens. In addition, the European
Commission's Joint Research Commission has been working on the
evaluation and comparison of allergen methods currently on the
market and the development of certified reference materials to
improve the performance of existing and future methods.
LIST OF
PROJECTS FROM
THE T07 RESEARCH
PROGRAMME
| Project code | Project Title
|
| T07001 | The prevalence and natural history of peanut allergy and investigation into its genetic, environmental and immunological determinants.
|
| T07002 | Development of food intolerance in atopic and non atopic families: influence of maternal nutrition and infant feeding practices in preterm infants.
|
| T07003 | Investigation of the immunological mechanisms in cow's milk sensitive enteropathy.
|
| T07004 | Do food additives cause hyperactivity and behaviour problems in a geographically defined population of three year olds?
|
| T07005 | The effect of exposure to food proteins via maternal sources in the development of food allergy in infants.
|
| T07010 | Cross-reactivity in peanut allergy.
|
| T07011 | Immunochemical reactivity to peanuts and nuts in allergic individuals.
|
| T07012/T07013/ T07014 | Investigation of the cross reactivities toward peanut and other nuts in relation to the age of the allergic individuals.
|
| T07015 | Peanut allergens associated with provoking clinical symptoms.
|
| T07016 | Investigation of Immune Responses to Food Allergens in Individuals with a Clinical Spectrum.
|
| T07018 | Allergen specific antibody binding characteristics and longitudinal serological changes to purified peanut allergens.
|
| T07019 | Do protein structures determine the allergenicity of the alpha-class family of plant proteins?
|
| T07022 | Can topical exposure to peanut antigens induce allergic sensitisation alone or in combination with mucosal exposure?
|
| T07023 | Prevalence and incidence of food allergies and food intolerance.
|
| T07024 | Development of a polymerase chain reaction based method for the identification of peanut in commercial products.
|
| T07025 | The characteristics of kiwi fruit allergy.
|
| T07026 | To investigate the influence of maternal experience of dietary antigen on the subsequent immune status of their offspring.
|
| T07027 | The interaction of food allergens with the epithelium of the alimentary canal: Investigation of non-immunological determinants of allergenicity.
|
| T07028 | The influence of dose and route of exposure on the early life origins of peanut allergy.
|
| T07032 | The role of IgG in allergy and tolerance to common food allergens.
|
| T07033 | The immunomodulatory role of maternal IgG in infant atopic programming.
|
| T07034 | An investigation into trends of peanut allergy incidence in the last 15 years in England using sequential childhood cohorts.
|
| T07035 | The prevalence of peanut allergy in British children at school entry age in 2003.
|
| T07036 | Development, recognition and significance of IgG antibodies in allergic sensitisation and adverse reactions to peanut.
|
| T07037 | Fatal Asthma from Food Allergy.
|
| T07038 | The characteristics of kiwi fruit allergy.
|
| T07039 | Aberrant mast cell signalling as a cause for anaphylaxis.
|
| T07040 | Chronic and Acute Effects of Artificial Colourings and Preservatives on Children's behaviour.
|
| T07041 | The role of peanut-specific T cell responses in children with peanut allergy and in children who are tolerant to peanuts.
|
| T07042 | Longitudinal Study of T cell responses in development and resolution of Food Allergy.
|
| T07043 | Peanut allergy: routes of pre-natal and post-natal exposure.
|
| T07044 | Peri-natal egg and milk allergen exposure patterns and the development of tolerance or allergic sensitivity to food in infancy.
|
| T07045 | Food Allergy and Intolerance Research—qualitative research into the information needs of teenagers with food allergy and intolerance.
|
| T07046 | The prevalence of food allergy and weaning practises in a birth cohort of UK Infants.
|
| T07048 | Systematic review on tolerable levels of gluten for people medically diagnosed with coeliac disease.
|
| ZT0702 | Allergy Database Service.
|
Annex III
FOOD LABELLING—STATUTORY
AND VOLUNTARY
1. The UK has been pressing the EU for improved labelling
of allergenic ingredients in food for a number of years. In 2003,
an EU Directive was agreed that required the labelling of 12 specified
allergenic foods and their derivatives, whenever they are used
in pre-packed foods, regardless of the level of use. A key element
of this new legislation was the removal of the exemption in the
previous labelling Directive, whereby the ingredients of a compound
food ingredient (such as a sponge finger in a trifle, or slices
of sausage on top of a pizza) did not have to be declared if the
compound ingredient made up less than 25 per cent of the final
food product.
2. This list of allergenic foods was based on advice
from the European Food Safety Authority (EFSA) about the foods
that are of the greatest public health concern across the European
Union countries. This list currently includes the following allergenic
foods and any ingredients derived from them:
— Cereals containing gluten
— Sulphur dioxides and sulphites at levels above
10mg/kg or 10mg/ml, expressed as SO2
3. This European Directive (2003/89/EC) came into force
in November 2004 and products not complying with its requirements
were prohibited from November 2005. A further Directive (2005/26/EC)
was agreed in March 2005 that exempted certain ingredients derived
from these allergenic foods from these labelling requirements,
on the basis of evidence that they were no longer allergenic.
4. The European Commission has recently agreed that this
list of allergenic foods should be extended to include molluscs
and lupin, as there is advice from EFSA that these also present
a public health concern. The national implementing legislation
will be amended in due course once the EU Directive has been published
in the Official Journal, which is expected to be before the end
of 2006.
5. The statutory legislation described above does not
cover unintentional cross contamination of a food with an allergenic
food at some point during production. Many food manufacturers
voluntarily provide information on such a possibility with advisory
labels using phrases such as "May Contain Nuts". The
Agency has conducted consumer research, which demonstrated that
many consumers find the variety of phrases used for such labelling
confusing, and are concerned that they are overused, and many
therefore ignore such warnings. The Agency was also approached
by food industry trade bodies asking for advice in this area.
6. The Agency has worked with all the relevant stakeholders
to produce best practice advice on allergen management and consumer
information, and this was published in July 2006. This guidance
helps businesses assess the risk of possible allergen cross-contamination
of prepacked foods and also advises them on how such risks can
be reduced or eliminated, so that advisory labelling is only used
when there is a real risk of cross-contamination that cannot be
controlled. The guidance also advises on the phrases to use if
such warnings are appropriate, as research has shown that consumers
were confused by the wide range of advisory labels currently in
use.
7. Foods that are not prepacked (that is foods that are
sold prepacked for direct sale or those sold loose, including
foods sold in catering establishments) are also exempt from most
food labelling legislation, including the allergenic ingredients
labelling legislation described above. There is clinical evidence
to indicate that foods sold in this way are more likely to be
the cause of adverse reactions to foods than foods sold prepacked.
In addition, responses to public consultations have indicated
that there is strong consumer demand for more allergen information
for foods that are not prepacked.
8. The Agency produced advice for caterers on food allergy
that was published on the Agency website in May 2004[15].
The Agency is now working with relevant stakeholders to produce
best practice guidance on the provision of allergen information
for foods that are non-prepacked. A public consultation on draft
guidance was issued on 5 July and closed on 27 September 2006[16].
The responses received will be assessed and the draft guidance
amended as necessary. It is anticipated that the final guidance
will be published in Autumn 2007.
REFERENCE LIST
[NOT PRINTED]
31 JANUARY 2007
5 October 2006
1
Section 1(2), Food Standards Act 1999. Back
2
http://www.hesonline.org.uk/Ease/servlet/ContentServer?siteID=1937&categoryID=214 Back
3
http://www.food.gov.uk/science/research/researchinfo/foodcomponentsresearch/allergyresearch/t07programme/t07projectlist/ Back
4
http://www.food.gov.uk/multimedia/pdfs/t07review.PDF Back
5
http://www.food.gov.uk/multimedia/pdfs/stratplan0510.pdf Back
6
http://www.food.gov.uk/news/newsarchive/2003/feb/boardmeetingnewsfebruary2003 Back
7
http://www.food.goc.uk/news/newsarchive/2003/sep/boardupdatessept122003 Back
8
http://www.food.gov.uk/aboutus/ourboard/boardmeetings/boardmeetins090904/boardminutes090904 Back
9
http://www.food.goc.uk/news/newsarchive/2006/apr/openboard0406 Back
10
http://www.food.gov.uk/multimedia/pdfs/avoiding food.pdf Back
11
www.eatwell.gov.uk Back
12
http://www.food.gov.uk/asksam Back
13
http://www.food.gov.uk/multimedis/pdfs/rrd21 Back
14
http://www.europrevall.org/ Back
15
http://www.food.gov.uk/safereating/allergyintol/caterers Back
16
http://www.food.gov.uk/consultations/ukwideconsults/2006/allergeninfoconsult Back
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