If you have food allergies, you may know that Health Canada plays a role in food labelling, inspection and enforcement. Over the years, Food Allergy Canada has been in contact with Health Canada and has provided feedback on positive changes related to labelling and other issues affecting people with allergies. Health Canada takes a proactive role to protect all Canadians and we are proud to be a part of that process.
We sat down with representatives of Health Canada recently and asked them 5 questions about their work. All our questions are inspired by Food Allergy Canada member input.
What is the main role of Health Canada in food labelling, especially in relation to food allergies?
Health Canada: Health Canada is responsible for establishing science-based regulations, guidelines and policies, including those related to the labelling of food sold in Canada. Requirements for labelling of food sold in Canada are set out in the Food and Drugs Act and the Food and Drug Regulations. The intent of the labelling regulations is to provide Canadians with the information they need to make informed choices about the foods they eat.
Health Canada works closely with the Canadian Food Inspection Agency (CFIA) on issues related to food labelling, including the declaration of food allergens on the labels of prepackaged foods. The CFIA is responsible for all federal food inspection activities and the enforcement of federal labelling regulations.
The government of Canada has 10 Priority Allergens in labelling. Can you explain what this means?
Health Canada: Health Canada typically refers to the following as the “ten priority allergens”: eggs, milk, mustard, peanuts, seafood, sesame, soy, sulphites, tree nuts, and wheat.
Seafood refers collectively to fish, crustaceans and shellfish. The tree nut category includes nine specific tree nuts: almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachio nuts, and walnuts. [Because sulphites] can cause allergic-type symptoms in sulphite-sensitive individuals, they are included among the “ten priority allergens”. Finally, “wheat” includes triticale, a grain that is a cross between wheat and rye.
Representatives from Health Canada, the CFIA, allergy associations and the medical community originally identified the list of ingredients most frequently associated with severe adverse reactions. This list included all of the above except mustard. Mustard was subsequently added to the list, in 2012, based on a review of the scientific evidence.
The priority allergens are covered by enhanced labelling regulations, which go above and beyond the normal requirements for declaration of ingredients.
In the past few years, Health Canada changed some labelling requirements for packaged food. Can you explain what changed?
Health Canada: In August of 2012, amendments to the Canadian Food and Drug Regulations came into force. These amendments were designed to enhance the labelling requirements for priority food allergens, gluten sources and added sulphites.
Prior to the amendments of 2012, labelling of priority food allergens was treated like any other food ingredient. They had to be declared by their common name on the label of most pre-packaged foods when they were used as an ingredient, however they were also subject to labelling exemptions in certain situations. Some multicomponent ingredients are exempt from declaring all of their components (sub ingredients) when present in another food. Also the common name of some ingredients may not be readily identified by many consumers as being derived from a food allergen.
Under the enhanced labelling regulations, labelling exemptions do not apply to priority food allergens. Ingredients that are derived from priority food allergens now must be listed in a manner that identifies the common name of the allergen. For example, the presence of egg must be identified as “egg”, when a product contains ovalbumin [which is derived from egg]. Some ingredients used in food products which were previously exempt from declaration in the list of ingredients, (e.g., components of margarine, seasoning and flour) are now required to appear on food labels also.
What about “May Contain” or “Contains” statements in Canada? Are they voluntary or required?
Health Canada: A manufacturer who is aware of potential cross contamination with priority food allergens has a responsibility to either change the way the food is being manufactured in order to eliminate the risk of cross contamination or to warn the allergic consumer using a precautionary statement. Since 2012, Health Canada has recommended the use of the wording “May Contain” for food allergen precautionary labelling but other statements are allowed as long as they are truthful.
[Ed. note: “May Contain” statements are recommended, but they are not required].
If a manufacturer does choose to use a “Contains” statement, it must appear immediately after the list of ingredients and must list all of the priority food allergens, as well as gluten sources and added sulphites, that are present in the product.
A food allergen precautionary statement, such as “May Contain”, is a declaration on the label of a prepackaged food of the possible inadvertent presence of an allergen in the food. As with all labelling statements, precautionary statements are subject to Food and Drugs Act (the Act). The Act states that foods cannot be labelled in a manner that is false or misleading. More information on food allergen precautionary statements can be found on the Health Canada website here.
What happens when someone has a reaction and reports the food product to the CFIA as potentially containing an unlabeled allergen?
Health Canada: When the Canadian Food Inspection Agency (CFIA) receives a report of an adverse reaction, CFIA officers will begin to conduct a food safety investigation in order to gather as much information as they can about the product, where and when it was purchased, details of the adverse reaction, etc. If necessary, the CFIA will gather and analyse samples of the food product.
The CFIA then transfers all of the pertinent information to Health Canada for a health risk assessment. Health Canada considers the potential hazard posed by the product, the amount of the allergen that could be ingested, and the likelihood that the product could be consumed by someone with a food allergy. Health Canada’s conclusions are used by the CFIA to help determine the most appropriate action for the particular situation in order to eliminate or minimize potential risks, if any, to allergic consumers.
Actions may include a request to the regulated party to conduct a food recall and the posting of a food recall warning by the CFIA.
Thank you so much for answering all our questions. This is great information!
- To get information about food recalls, join our Allergy Information Service. You can also follow the CFIA on Twitter @CFIA_food
- A guide to understanding food labelling in Canada
- How to report a reaction to the CFIA
- Learn more about Health Canada
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