It has now been one year since amendments to the Food and
Drug Regulations enhanced the labelling of food allergens in
Canada. Although reports don't reveal a dramatic increase in
the frequency of allergen-related recalls, surprisingly the most
common category of recalls since the new requirements came into
force was undeclared mustard.
As discussed in Ron Doering's recent
article in Food in Canada, "Can't cut the mustard – it's
everywhere" this result is due to the addition of
"mustard" to the list of 10 priority food allergens. The
revised Regulations require manufacturers to clearly
identify food allergens, gluten sources, and sulphites either in
the list of ingredients or at the end of the list of ingredients
with the following statement "Contains: ...".
Manufacturers must also now list components of ingredients if they
contain food allergens, gluten sources, or sulphites. As Ron notes,
this "corrects past situations in which manufacturers
didn't need to disclose the presence of an allergen if it were
contained within what they listed as spices, flavourings or
seasonings." The new requirements have, in practice, presented
quite a challenge for food manufacturers since frequently suppliers
do not disclose the various components within the these
ingredients. As a result, the new requirements will require more
information sharing between manufacturers and
A review of the recalls in the past year also indicates that
manufactures and importers should be wary of the potential for
cross-contamination as the CFIA may increase the class assigned to
a recall and require a recall to the retail level if the presence
of an undeclared allergen has resulted in an adverse reaction. It
is important to note that with the exception of gluten, where CFIA
has indicated that enforcement action on products containing less
than 20 ppm gluten from cross-contamination will not include a
recall of the product (see Compliance and Enforcement of Gluten-Free
Claims), there are no threshold levels for allergens.
While Lowest Observed Adverse Effect Levels (LOAELs) for food
allergens can give us an idea of what levels have been associated
with adverse reactions in the past, (see pg. 54 of FDA's Approaches to Establish Thresholds for Major Food
Allergens and for Gluten in Food) these values should not
be considered absolute threshold levels as there are too many
uncertainties regarding the levels that people can react to, and
the amounts being detected and quantified by testing.
The prospect of an internal investigation raises many thorny issues. This presentation will canvass some of the potential triggering events, and discuss how to structure an investigation, retain forensic assistance and manage the inevitable ethical issues that will arise.
From the boardroom to the shop floor, effective organizations recognize the value of having a diverse workplace. This presentation will explore effective strategies to promote diversity, defeat bias and encourage a broader community outlook.
Staying local but going global presents its challenges. Gowling WLG lawyers offer an international roundtable on doing business in the U.K., France, Germany, China and Russia. This three-hour session will videoconference in lawyers from around the world to discuss business and intellectual property hurdles.
Effective September 1, 2016, the Disposition of Surplus Real Property Regulation to the Ontario Education Act was amended with the intention to reduce barriers to the formation of health and community hubs in Ontario.
Health Canada is proposing to change the way that it regulates non-prescription drugs, natural health products and cosmetics in Canada, which will now be referred to collectively as "self-care products."
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